Bean to bar chocolate makers

Jeez...I am now starting to "get" that I am starting to be grouped with the Xocai folks. PLEASE DON'T MAKE THE MISTAKE OF DOING THAT! I have been into raw foods since 1993, LONG before raw chocolate was promoted as a superfood by David Wolfe and his book on the subject, Naked Chocolate. David Wolfe was invited to become part of Xocai at their startup in about 2005, and he declined for reasons I will not mention.

Yay!

Dear Samantha,Honestly, I am a chocolate newbie compared to you, and don't claim in any way to know as much as you do on the subject of chocolate. I only got started in 2005, and didn't finish building our factory until the end of 2006. That being said, I do have hard evidence on my claims of antioxidants done by an independent and reputable lab. The lab report is published on our website and I am happy to email it to you privately if you wish to see it. I am not trying to ram anything down anybody's throat and your negative response definitely is pointing out that you must be getting your buttons pushed or something? I am just standing up for what I believe in. Everybody is entitled to their own opinion and that includes both you and me. You may know a lot more than me about chocolate, and the very idea that I may even know one thing that you do not I feel is upsetting you to the point that you feel you have to put me down. Hearts, Sacred Steve
updated by @sacred-steve: 09/09/15 18:56:31

FYI...We have discovered a new way to make chocolate starting from the whole cacao bean. We do not make chocolate from cocoa liquor.

Hi Michael,Thanks for your concern. We are ALL about full disclosure with ingredients. We have even signed the truth in labeling oath with the natural ingredient resource center. I have yet to see another chocolate company do the same. As such, we list in our ingredients three types of ingredients: Cacao Nibs, Cacao Butter, and Whole Cacao Beans with SKINS. Also, we list our "milk" chocolate as Mylk with a y so that we indicate to consumers that our Mylk chocolate tastes like milk chocolate even though it is actually dark chocolate. If companies can even include such things as hydrogenated vegetable oil, whole flowers, salt or even bacon in their chocolate and call it chocolate, there is a disconnect at least within my own mind of how something that is as raw and natural as the actual whole cacao bean itself can't be called chocolate if it is included in the very thing it is responsible for making. We in no way want to mislead consumers. Instead we want to fully educate them. This is why I give tours to children of the factory on a regular basis and actually make chocolate with children from bean to bar. We choose to include the husks of the bean in our chocolate because they have been cleaned in a proprietary way which allows such, and because like the skin or husk of a sesame seed, we believe there is much nutrition that is otherwise lost. The chocolate industry, chicken farming industry, and fertilizer industry recognize at least some nutritional value in these husks because they are used in these other industries. By doing something outside the box and new, I am sure we will run into existing structures (including the FDA) that say we can't for many reasons, the least of which is that it just hasn't been accounted for yet. Every computer program will eventually crash because there is no way it can account for all unknown future cases. We are basically that computer crash.All the best,Sacred Steve

Steve,I am not a lawyer, but I do think you should consult one. I think you are in violation of Federal labeling law. I believe you need to make up some sort of name for your product. It legally isn't chocolate. (Maybe you could call it Chocolate with Cocoa Husk)The standards of identity are not concerned with safety at all. They are about full disclosure to consumers. They also provide for fair competition and prevent a product from dilution. If there were no distinction between chocolate and for example chocolate compound consumers could easily be misled into thinking they were paying for a premium product and actually purchasing something diluted with hygroginated vegitable fats. If they dislike compound coating they might frown upon all chocolate. That hurts business making a the "real" thing.This isn't an attack on your product. I haven't tried it. It may be very good. However, the standard set by the FDA isn't about making value judgements. It is about making sure we all are speaking the same language when we use words like "chocolate" or "sugar".Interestingly if you include less than 12% milk solids in a chocolate bar you can't call it a "Milk Chocolate." So if you have a bar with 9% milk you may need to call something fanciful like "Mike's Bar" and then have a clear description of what the product actually is comprised of on the front label.best of luck,Michael

are you going to taste some of our chocolate?
updated by @sacred-steve: 01/24/15 07:39:21

No thanks.Are you going to answer my questions?Andrea

You should order some of our chocolate

You are selling interstate, are you not? If so then you are governed by the USDA and FDA and must adhere to their rules. The State of California can only make exemptions if you are selling strictly within their boundaries.What exactly do you mean you are listed with the USDA and FDA?Andrea

Steve:To many people, the claims you make for your product are no different than the claims made by MXI for Xocai - because they are shrouded in secrecy.What you're encountering here is the same kinds of skepticism. If you want to stop people from questioning you about this you're going to have to be much more open. For example, your iron claim. Do you have an independent lab assay (e.g., Brunswick) showing the differences in iron content in your product made with and without the shell to back you up? If you do - just post it so people can see that it's real. That's all anyone is asking. We're not asking you to reveal your proprietary machinery and processes - just to back up the claims your are making for the results of your processes with independent support.What's hurting MXI (at least for members here on The Chocolate Life) is that a lot of the information they do publish is just plain wrong, and they're squirrely about the patents that cover their claims for cold processing. It smells fishy, and fishy-smelly chocolate is not a pleasant thought. (Though did you know that MXI uses hydrolyzed fish collagen in one of their products? Great protein source I am told though not very appealing from a dietary or sensory perspective.)Another thing that's hurting MXI is that the lab test they reference is several years old. To be valid, in my opinion, they need to run an assay on every batch because they make a very concrete claim for ORAC levels. The only reasons MXI gets away with this are a) they are claiming to be a dietary supplement not a food "this product is not intended to diagnose or cure any disease" and b) there is no RDA (recommended daily allowance) for ORAC.Being on the cutting edge does not exempt you from federal regulations. In cases like this my understanding is that the FDA supersedes California authority.


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Clay, if we don't make chocolate, i don't know what it is then! And, perhaps you should not have allowed me in your chocolate competition. Steve

By the way, you don't have to start from cocoa liquor to make chocolate. We START from the whole bean.

Steve:Have you run your interpretation past a lawyer who has experience arguing these kinds of cases with the FDA?All chocolate is, by definition, made from chocolate liquor. Chocolate liquor, by definition, is made from nibs. There is no provision for making chocolate from whole beans. Here are the references:Sec. 163.111 Chocolate liquor.(a)Description. (1) Chocolate liquor is the solid or semiplastic food prepared by finely grinding cacao nibs.Sec. 163.110 Cacao nibs.(a)Description. (1) Cacao nibs is the food prepared by removing the shell from cured, cleaned, dried, and cracked cacao beans.Sec. 163.123 Sweet chocolate.(a)Description. (1) Sweet chocolate is the solid or semiplastic food prepared by intimately mixing and grinding chocolate liquor ...^ included is the definition of sweet chocolate is bittersweet chocolateEven though you're grinding whole beans you are subject to the rules related to shell content if you want to call your product chocolate. Right now, because you're not making your product from nibs, legally you can't call it chocolate. That's the way the Standards of Identity work. They determine what ingredients can be included in a food (and in many cases HOW it is made) if you want to use a certain word or term to describe it. Because your products use a process that is not in the Standard of Identity, my interpretation is that your product does not adhere to the Standard and therefore can't be called chocolate.But - I am not a lawyer and YMMV.:: Clay


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Like I said, we ARE on the CUTTING edge...please read my reply to Clay regarding the State of CA. We are not here to "break" the rules. Our goal is to marry EXCEPTIONAL flavor with EXCEPTIONAL nutrition, and a HUGE amount of the nutrition of the bean is in the Husk. Just like the skin of a sesame seed, skin of a cucumber or potato or orange, a lot of nutrtion is in the husk. For instance, the Cacao Bean is VERY high in iron, however, most of that IRON is in the husk. That is just one example. Our beans are harvested in a very proprietary fashion so that they are extremely clean. They are sold at retail as whole beans with skins for human consumption they are so clean. They actually look like almonds and are mistaken for such CONSTANTLY at our demos and tastings. I am happy to email you a picture separately and privately if you wish.

http://www.accessdata.fda.gov/SCRIPTs/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=163.111 (a)Description. (1) Chocolate liquor is the solid or semiplastic food prepared by finely grinding cacao nibs.So in order to make cocoa liquor you must grind nibs as defined by the Standards of Identity. You must use cocoa liquor to make chocolate......You can word it however you like, but you are not following the FDA guidelines to be able to call it chocolate. My problem with this is that there is a reason we have these guidelines. So you skip the one tiny detail. Big deal right? I find it is a huge deal, if it becomes standard to ignore federally mandated regulations that are set up to preserve the quality of American chocolate. What exactly makes your company exempt from following the same rules everyone else must follow?Andrea

FYI. We are under close supervision by the STATE OF CALIFORNIA Health Department on this. They are WELL aware of what we are doing, which is on the cutting edge of chocolate making in my opinion. We have supplied them with CofA's of our cacao beans showing all microbial analysis and water activity which is well below acceptable limits. To date, nobody has fallen ill from our chocolate. We have been in biz since the summer of 2006 with a 100% perfect record. We are also listed with the USDA and FDA.

This is a common misunderstanding that we get accused of all the time, and I always have to point out the issue. The FDA is DEFINING a cacao nib, not chocolate. Of course, the VERY DEFINITION of a NIB, hinges on the fact that the HUSK is removed. Otherwise, it is still technically a bean if all the HUSK material is still included. What the FDA has done here is basically given a guideline to what a cocoa processor is allowed to leave in the finished NIB batch as far as leftover husks is concerned. As any bean to bar maker knows, it is VERY difficult to get 100% of the husk removed from the bean in any sort of automated process. The FDA is allowing some leeway here... (chocolate is a much different definition from cacao nib.)Sec. 163.110 Cacao nibs.(a)Description. (1) Cacao nibs is the food prepared by removing the shell from cured, cleaned, dried, and cracked cacao beans. The cacao shell content is not more than 1.75 percent by weight, calculated on an alkali free basis, as determined by the method prescribed in 163.5(a).

Oh ok. If that is the case, Sacred Chocolate is a bean to bar maker. Hearts,Sacred Steve

Andrea:You are technically correct on this one. It makes no nevermind that they are making raw chocolate - they still need to be in compliance with the FDA standards of identity in order to call their product chocolate.However, the company is so small that the FDA is not likely to take any action unless it becomes a food safety issue, i.e., someone files a complaint because they believe they got food poisoning from eating it.:: Clay


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http://www.accessdata.fda.gov/SCRIPTs/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=163.110 "The cacao shell content is not more than 1.75 percent by weight"As far as I can tell, leaving the husk in means you cannot call it chocolate.Can you please tell me if I am wrong since you are a Raw company? I assume you have to follow FDA guidelines in your labeling?Andrea

Steve:If you take a look at my reply to Gretchen, you'll see that whether or not a specific step (e.g., roasting) is done is not at issue here.The point is that you start with beans and end with finished chocolate and that all of the steps that are undertaken to get from Beans to Bars, for each and every batch, are performed or personally (as in in-person) supervised by the company making the claim.:: Clay


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Gretchen:I think that there is a consensus that in order to accurately use the term bean-to-bar, the company must start with beans and end with finished chocolate for wholesale/industrial AND/OR retail sale. Wrapped and boxed bars or liquor (liquid or no), the final form is not the significant issue.The question is - do they have to OWN ALL of the equipment or can they contract out some of the operations as long as the work is being done under close supervision?In the end, I really don't care about the ownership of facilities issue as long as they are open and upfront about what they are doing - AND a company employee actually supervise each and every roast, grind, molding, etc. The moment they're no longer personally supervising each and every step of every batch they're contracting with someone else to do then, IMO, they are no longer bean-to-bar.I am more interested in protecting the use of the terms, "origin" and "single-origin." From my perspective it's not a true single-origin bar if there is any added cocoa butter that is not from the same origin. So, the practice of using deodorized cocoa butter of unspecified origin in a recipe means that the chocolate is no longer single-origin, it's "origin chocolate with added cocoa butter of uncertain provenance."Again, I am cool with this as long as people are up-front about it and specify the percentage of added cocoa butter that is not from the origin of the cocoa mass.:: Clay


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updated by @clay: 09/07/15 10:40:05

Aequare does not make chocolate from beans, however they are one of the few chocolatiers exporting into the US who makes confections using ingredients sourced almost exclusively in the country of origin.Aequare does work (in an advisory capacity and as a customer) with an independent grower in Ecuador who converts a portion of his crop into chocolate at a factory in Guayaquil. This grower also buys from other local growers and converts a portion of what be buys into chocolate, too.ChocolateLife member Jeffrey Stern is the founder of the company. He was born here in the US and spent years overseas working for USAID before catching the confectionery bug. His wife is Ecuadorian so they moved there several years ago with their young family. Aequare has a workshop and retail operation (Gianduja Chocolatier) in Quito and their product is available on-line and in some stores here in the US.:: Clay


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Hi Gretchen,Not sure if there was any official decision made?We are a bean to bar maker (we even include the husks/skins of the bean) in our chocolate since our beans are so clean they look like almonds. However, we don't roast or cook the beans in any way so that we can retain the very high anti-oxidant value that is naturally occuring in the raw bean. So, we may be an exception to any official rule.Hearts,Sacred Steve

Hi,I wondered whether there was decision made in a later discussion thread that confirmed that bean-to-bar was only accurate if they roasted their own beans?

Is Aequare, http://www.aequarechocolates.com/ , a bean to bar chocolate maker? They seem to be advertisers on TCL.
updated by @chocofiles: 01/24/15 14:34:43

I'm not conviced Cadbury is a B2B Company.

Cadbury is? Definitely did not know that. I love Cadbury though, and their commercial is hilarious! http://adwido.com/view_content?vkey=9be0f455ddd4b4cb77ad70596090d38e

Must be a cost issue. Italy is a relatively expensive place to do business. Poland doesn't have much of a history with fine chocolate, but everyone is using the same equipment and people can be trained ...


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Clay, I've heard Green and Black's now is made in Poland. It seemes ICAM no longer is a partner.

Masur,Thanks for catching that. I made the changes in the text part of the document. They weren't listed in the table, which is the main reference I use.BTW, Mars is listed as a b2b company. I have no idea where I got that info, but it seems hard to believe. Is it right? Is Mars a b2b company?

I can confirm that Green and Black's does not do their own manufacturing - it's done in Italy. Dolfin uses couverture from Belcolade.


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Nice effort Olorin but Green & Blacks is not a bean to bar company, nor is Cafe-Tasse and Dolfin according to my sources.

I've attached a Word document that has a list of Bean to bar makers, and a list of Fondeurs. It's compiled from information I've collected from TCL, from friends, and from the internet. Someone may want to add these companies to the TCL database.Please let me know if there are is any mistaken information in it, so that I can correct it.

Thanks for the update.About the printout. At the moment, no. But I am looking into a way to do that.


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What a Great resource! Thanks!A correction: DeVries is in Denver CO, not Boulder.Is there any way to print this data to get a hard copy?

Masur,Thanks for taking the time to research a little and answer my question.

I have re-posted the online Chocolate Makers database . It is an Add-Only database, which means you can only add an entry, not edit them. This is an international directory, not just US companies.If you have any questions or comments about an entry, please submit them in this forum so that they can be make public. I will make the changes as they are brought to my attention.


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Being a micro-batch bean to bar company ourselves, i can vouch for the difficulty in doing HIGH QUALITY bean to bar in the USA without cutting corners while bringing to market a retail price point below $4 which is most of these companies. I don't blame them for not being bean to bar. It seems most grinding is being done offshore these days except for some of the hugely automated stateside comanies with massive infrastructure investment.

Cote dOr is owned by Kraft Food and not a bean to bar company. I've never seen bars from Equal Exchange and Rapunzel. A Check at their websites convinced me they are not bean to bar companies.

Does anyone know if any of these companies are bean to bar?-Cote dOr-Equal Exchange-Rapunzel