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

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).

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.

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

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.

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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clay - http://www.thechocolatelife.com/clay/

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

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

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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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

You should order some of our chocolate

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

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

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

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

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

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

Yay!

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.

Steve -The fact that you're being grouped in with the Xocai folks can be laid, in part, at your doorstep. Your marketing of your product (and yourself) appeals to people who have already bought into your central concept. For people who have not already bought into the claims made for the raw lifestyle the claims you make - and the way you make them - comes across as unsubstantiated hype.Now there might be a real difference that makes a difference in what you do. And I, for one, am willing to do some heavy lifting and be patient, and try to understand. Many people will just dismiss it as being kooky or weird.What you may want to remember is that perception is reality for most people. And the perception that many people outside of the raw foodist community have is NOT the one you want them to have. Saying exactly the same things over and over and over again is not going to change their minds. If you are interested in winning them over you have to change the way you present your product, your company, and yourself.I say the following as a colleague and a friend - and as someone who has friends in the raw food and raw chocolate world:Now - you may not care about non-raw-foodists and from a business perspective I can understand that. However please understand that people are lumping you in with Xocai because they don't see any difference in the claims you are making and how you make them. Again - if you care - you are the only one who can move to change this perception. As I said, you may not care, but from my 15+ years of research into chocolate, chocolate marketing, and more, the burden is yours to convince us, not on us to understand you.


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clay - http://www.thechocolatelife.com/clay/

Because of the spill over between this thread and the thread on enzymes in cacao I am temporarily closing this thread to further comments to give things a chance to calm down.


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clay - http://www.thechocolatelife.com/clay/

Is Alter Eco a bean to bar company?

I'm currently reviewing several of their bars. The beans are grown by the El Ceibo Cooperative in Bolivia and the chocolate is made " in the pure Swiss tradition " by someone in Switzerland.

Lowe ... Alter Eco is a US-based product sourcing and marketing company. If the bars are made in Switzerland, then how can Alter Eco be bean to bar?

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I guess I should have done more research on the internet first. I was only looking at the package which says in large bold letters on the front "El Ceibo Cooperative" then on the back "Made in Switzerland" and distributed by "Alter Eco Americas". Going by this information alone I thought it would be possible for the company to be bean to bar, made in Switzerland but distributed in the U.S. Now I wonder-- who actually makes the Bolivian beans into chocolate?

It turns out that Alter Eco is a French company started in 1999.

Clay, thanks clarifying this.

I've updated the database with Rogue Chocolatier, from Minneapolis, MN. The founder, is the youngest chocolate maker that I know, and if I'm not mistaken, Colin Gasko is also a TCL member too. Can't wait their chocolates, that I've ordered, arrive in my home in January :-p

I make chocolate from bean to bar in the UK - Red Star Chocolate. Clay has even tasted some of it...

Hi Duffy

Yes, and I've read about you at Seventypercent.com, wanna taste yours too, but I can't order them from my country *sigh*

Someday when I can make it to Europe and UK, I will definitely go to your workshop to learn and taste some sample, if you don't mind

Willy

Just for fun, here is the ICCO (International Cocoa Organization) of "Chocolate Manufacturers." In looking at it I see:

• None of the American craft chocolate makers on the list (e.g., Amano, Askinosie, Black Mountain, Cacao Atlanta, Escazu, Patric, Rogue, Theo ...).
• Some other amazing oversights - Pralus, Bernachon, Debelis, Ambrosia, Belcolade,
• Some companies that clearly don't belong on the list (Green and Black's - until recently, anyway, all G&B product was made by the Italian company ICAM; Astor, Asher's).
• Does Scharffen Berger count any more (as manufacturing is supposedly done by Hershey). Dagoba as well?

It's not clear what the criteria are for inclusion. One very new company, AMMA (Brazil) is on the list.

Thoughts?

:: Clay

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Thank you for sharing this information about Bean to bar chocolate makers.

Well thank god somebody thought to include Trader Joe's!

Not sure whether these guys can be classified as bean to bar yet but they seem to be heading in that direction.

Farm by Nature
Phone: 392128188
Website: http://www.farmbynature.com.au/

When it comes to the Cocoa itself, Farm By Nature is on the road ( through their sister company Cocoa Australia)
to grow Australias first cocoa Plantation in Far North Queensland.
The first of these little Aussie beans should be available in 2010 and used to create a unique Australian Cocoa Farm Range.

Cocoa Australia nolonger exists there was some legal issues. However the plantations still exist and there are some exciting things hopefully to happen in 2011 up in FNQ. I can't say more as it is not my place, but I will when I can.

http://australianrawqacao.com/australian-raw-qacao-cacao-fruit-bean

This site purports to sell raw organic Australian beans already.

updated by @ice-blocks: 01/24/15 16:14:51

Yeah, I saw that the other day too, don't know who those hippies are, I'll have to ask.

Unfortunately, the content of the site is so poorly written, edited, proofread, and fact-checked that it's self-marginalizing and comes off as very fringe - even farther out than most on this subject. It will be interesting to see how the business takes off.


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clay - http://www.thechocolatelife.com/clay/

I've found and Australian Certified Organic farm listed as producing Cocao in Killaloe QLD but as yet had no reply from them.

RE: http://australianrawqacao.com/australian-raw-qacao-cacao-fruit-bean

Qacao sounds to me like a lot of Quackery mixed with spiritual mumbo jumbo.

updated by @chocofiles: 09/07/15 18:28:16

Is Bernard Castelain a bean-to-bar maker or a fondeur? Their website is only in French and I don't read French. I suspect that they're a fondeur but I don't currently have any evidence either way. All I know is that their chocolate wrappers don't say anywhere that they are b2b.

I wonder if we ought to add Mindo, Snake and Butterfly, Potomac, Salazon, all newer US makers claiming to be b2b, but I have not exactly called them up to quiz them... Isn't there someone on this list also who says they make b2b, Oakland Chocolate Company?

This list is going to be getting so long as small b2b increase exponentially over the next years, so can I just add my grandma's home brew now? She sells to her Mahjong club.

Thanks Casey. I've added a few of those that I didn't have to my personal list of b2b companies. I've got a list of 284 companies that are bean to bar, fondeurs, or some mixture. Some I don't know what they are.

Is Vivani in Germany a bean to bar company? I suspect that they are fondeurs, but I'd like to make sure. I gleaned from their website that they are owned by Ludwig Weinrich, and marketed by their subsidiary EcoFinia GmbH. They said that Weinrich has made chocolate for over 100 years, but they make no mention of actually being b2b. In addition, my very low enjoyment of their dark chocolate (72% bar, my enjoyment rating = 2 out of 10.) makes me suspect that they didn't make it themself. Does anyone have any more information about this?

I added those I mentioned in my reply just above to the master list, plus made made these and all the other newer additions hyperlinks. I have not added Salazon, as I'm slightly suspicious of this company.

For example, this from their FAQ

"Why dont you make milk chocolate?
At Salazon we see chocolate as an energy food not candy, so we simply stay away from offering sweeter, more candy-like milk chocolate. "

And what is their chosen default percentage for this "dark" chocolate? 54%!!

But that may be too bitter for many, so

"However, we do understand that some people may want a touch more sweetness so we created our Organic Dark Chocolate with Sea Salt and Organic Turbinado Sugar bar."

Also, there seems to be nothing on the website with any information on who these people are, not even their names, and no information about or photos of their chocolate making process. Except that they are the "Salazon Chocolate Co Team," which consists of "a group of us were on a backpacking trip to Utah."

Therefore, who knows who they are, or if they grasp "bean to bar" meaning.

btw, has anyone tried their chocolates? I see they are available at Whole Foods.