Forum Activity for @Clay

Sebastian - to reduce spam, you need to follow each other first.

Sebastian: I think others might want to know!

There is a persistent belief that white chocolate isn’t actually chocolate. Few places serve to perpetuate this myth more than the twin temples of the Internet: Twitter and Facebook.

The most commonly mentioned argument raised in any discussion of whether white chocolate is or is not chocolate is that it doesn’t contain any cocoa solids — what’s left over after the fat (cocoa butter) is removed from the paste made of ground up cocoa nib. Even though white chocolate does contain cocoa butter, somehow it’s not chocolate.

Let me set the record straight for anyone and everyone: white chocolate is chocolate. Really. Legally. This is not an alternative fact and it’s not subject to interpretation or subject to your personal feelings about taste or texture.

The proof can be found in Title 21, Volume 1, Subchapter B, Part 163 Section 124 (21.163.124) of the US Code of Federal Regulations, which contains the definitions (also called standards of identity) for Cacao Products. The very fact that there is a specific section in CFR 21.163 defining what white chocolate is should be all the proof anyone needs to realize that white chocolate is really chocolate.

§163.124 lays out the rules for what ingredients can - and can’t be - in a cacao product for it to be legally labeled as white chocolate. If a product conforms to the specifications listed in §163.124 it can be called white chocolate. Conversely, if it does not meet the definition it cannot be called white chocolate.

That naming bit is explicitly spelled out in CFR 21.163.124.6.C. Nomenclature: The name of the food is “white chocolate.” 

There are no ifs, ands, or buts. §163.124 is the definition for white chocolate and it is not open to second guessing.

Unfortunately, there is no entry in Snopes on this topic (though I have brought it to their attention), for those who are still skeptical.

You may not like it. You may not agree with it. But you are wrong if you persist in your belief that white chocolate is not chocolate. The only way around this is to change the law.

Ironically, most people don’t know that there is actually no legal definition for dark chocolate. What is referred to as “dark” chocolate falls into the category of “sweet” chocolate (§163.123). Unknown to most, §163.123 allows sweet chocolates to contain dairy ingredients, including:

• Cream, milkfat, butter;
• Milk, concentrated milk, evaporated milk, sweetened condensed milk, dried milk;
• Skim milk, concentrated skim milk, evaporated skim milk, sweetened condensed skim milk, nonfat dry milk;
• Concentrated buttermilk, dried buttermilk; and
• Malted milk.

And, just to make things even crazier, there is no formal legal distinction between semisweet and bittersweet chocolate.

Take a look at the front label on a bar of Hershey’s Special Dark® (45% cocoa content) Chocolate. You will notice that “Special Dark” is a trademarked term. Elsewhere on the front label you will find the phrase “mildly sweet chocolate.” This is to let regulators and inspectors know which section of CFR 21.163 the chocolate falls into. If you take a look at the ingredients list you will find milk fat and lactose (milk). Lactose is a milk sugar.

I am not making these things up. Go look them up for yourself. All of the above information about white chocolate is objectively factual. It has nothing to do with taste or quality, or whether you like it or not, §163.124 covers what can, and can’t, be in white chocolate as well as legally naming foods that conform to the regulation.

I won’t disagree with the observation that a lot of white chocolate is not worth the calories. What determines the quality of a white chocolate is the quality of the ingredients. What most people are thinking of when the think of white chocolate is the cheapest form of white chocolate imaginable, or a chocolate-like white-ish substance where some or all of the cocoa butter is replaced by another fat.

I agree. Ick.

Much of the appeal of white chocolate is the texture. Because there are no non-fat solids (the brown part), white chocolate is basically just smooth sweet fat. As a species, homo sapiens is genetically programmed to crave sugar and fat. When you add the experience of the way chocolate melts in the mouth, you have the potential for a perfect edible trifecta.

I can tell you from personal experience that white chocolates made with undeodorized cocoa butter (cocoa butter that has not had the flavor and aroma chemicals removed) will change your mind about white chocolate. They did mine.

I can tell you from personal experience that white chocolates made with exceptional dairy will also change your mind - assuming you are open to the possibility. Try white chocolate made with goat milk. Or white chocolate made with full-cream dairy produced by cows eating tender grass growing in sun-drenched alpen glades in early Spring and undeodorized cocoa butter.

But please don’t judge all white chocolate based on your {{ shudder }} experience with drug store easter bunnies.

In closing:

• Yes, there is such a thing as white chocolate.
• Be open-minded: don’t assume every white chocolates sucks just because the ones you’ve eaten suck.
• Don’t believe everything you read on the Internet. (But you can believe this.)

Mitch -

The regulations acknowledge that creating nutrition fact panels and designing packaging to accommodate them can be an onerous financial burden for small businesses, especially if they have lots of different products, each in different sizes.

Sebastian's lowering barriers to entry and complexity for startups and small companies are aspects of what I refer to as onerous burden.

The NLEA was enacted back in 1995. The tools to calculate the nutritional components of foods has improved a lot since then and the cost of generating the panels has come way down. There are now online services that will generate nutrition fact panels based on recipes you upload for $20 or less each.

So, I don't see that costs associated with generating the nutrition facts panel can be called onerous in this day and age, for many startup and small chocolate makers. 

If a chocolate maker has been in the market selling for a couple of years, I have trouble buying into the complexity argument as well. As I mentioned in the original post, if the recipes are substantially similar, a single label could be used for many products.

That said, if I were a confectioner with dozens and dozens of different pieces, some seasonal maybe never to be produced again, and which are produced in the low hundreds or thousands each, the complexity argument is very much in force and the economic argument becomes more compelling. In this case I don't see a problem with filing for the exemption if the company is eligible.

One possible motivation to consider is branding for a company whose packaging aesthetic is a large part of their appeal. Nutrition fact panels are ugly and putting one on the label (even on the back!) would interfere with the company's carefully crafted corporate identity. I personally do not buy that as a legitimate excuse.

Again, the operative point here - as I read it, and remember that I am not a lawyer - is that if you qualify for the exemption you must file for it to be in compliance with the law.

Where are you located? How many arms?

Recently, after seeing a photo of a Dick Taylor bar with a nutrition facts panel on it, I posted on Facebook asking how a company the size of the Mast Bros could possibly still qualify for a small business exemption from the 1990 Nutrition Labeling and Education Act (NLEA). With sales reportedly topping US$10M, a new 65,000sf factory under construction in the Brooklyn Navy Yards in NYC, a retail store in Williamsburg, a factory/store in the Arts District in Los Angeles, and who knows how many employees … how could the Mast Bros still be considered a small business?

As I learned after spending many hours poring over the regulations and reaching out to colleagues trying to make sense of the regulations, I learned that they probably do qualify for labeling exemptions for many, if not all of the products they make. I also learned that most small chocolate makers and confectioners are not filing for the exemption - and probably should be .

Disclaimer : IANAL - I am not a lawyer. This is my interpretation of the regulations. The analysis following should   not   be relied upon as reliable legal advice. You should consult a lawyer with experience with FDA labeling regulations. There are separate guidelines for foreign firms importing food products. Consult a lawyer.

Can YOU Qualify for a Small Business Nutrition Labeling Exemption?

Yes, Virginia, you are on the fast track to qualification if your company is incorporated in the US and it has an annual   average   of fewer than 100 FTE (full time equivalent) employees.

Any food company with an annual average of fewer than 100 FTE employees (seasonal employment can be higher) can claim an exemption for any product that is produced a)   in small quantities   and b)   as long as   the label: 1) does not contain any nutrition information;   and , 2) does not make a health or nutrient/nutrition claim.

If a product fails either of the above two numbered tests, a nutrition label is   mandatory – with   only one   exception [from the regulations]:

Foods in packages with available label space of less than 12 square inches (e.g. pack of gum),   provided that   the label provides a means for consumers to obtain nutrition information (e.g., address, phone number). However, if a nutrition or health claim is made, a nutrition label   must   be provided.

Statements such as “organic,” “sugar-free,” “gluten-free,” “dairy-free,” “soy-free,” and “non-GMO” are not likely to be considered health or nutrient/nutrition claims – but that depends on how they are worded. Sugar-free claims are subject to separate regulations. Statements such as “heart-healthy,” “high-fiber,” and “low-calorie” are likely to be construed as being either a nutrient content or health claim and would by definition require a nutrition facts panel on the label. It is not clear whether “paleo” (don’t get me started on how chocolate can possibly be considered paleo) or “raw” can be construed as a health claim, again it depends on wording. Consult a lawyer with experience in this area if you have any doubt.

What’s next?

Your company has fewer than 100 FTE employees and you are not making any nutrition, nutrient, of health claims on the label. There is just one more question to consider: what does the NLEA mean by “small quantities?”

The NLEA defines small quantities as “under 100,000 units   of ‘the same product’   sold in the same twelve-month period.” If you mold “the same” chocolate into (for example) bars in 5gr, 50gr, and 100gr sizes, you add up the total of all the different sizes and if the number is less than 100,000 then that product meets the quantity requirements for a nutrition labeling exemption.

However, if the total is over 100,000 then each size of the product needs a nutrition facts panel — unless the total area is less than 12 sq in, in which case you need to indicate, on the label, a way for the customer to get the information should they so desire.

Assuming your company and product(s) meet all the above tests, notice   must   be filed annually   with FDA   to be in compliance with the NLEA. There is only   one   exception:

Firms with fewer than 10 employees with sales of less than 10,000 units/product do not have to apply to FDA for an exemption.

Counting to 100,000 — the fine print

The above points seem straightforward … but one offers some wiggle room. The 100,000-unit number for a product refers to [taken from the regulations]:

A product includes all package sizes that are manufactured by a single manufacturer or which bears the same brand name, which has the same statement of identity, and has   a similar preparation method .  

In considering whether products have similar preparation methods, consider all steps that go into the preparation of the products, from the initial formulation steps to any finishing steps; for example,   products with different ingredients would be considered different food products and counted separately in determining the number of units.

But ... what do “different ingredients” and “similar preparation methods” (or,  recipe ) mean? This is where interpretation comes into play.

1. One way to interpret the guidelines would be to say that “all bars with 70% total cocoa content and with an ingredients list that consists of ‘cocoa beans, sugar’ and that are processed entirely in a melangeur” are   the same product   (or recipe; similar preparation methods and similar ingredient lists). This is   probably how an inspector would view things.
2. Another way to interpret the guidelines would be to say that “all bars with a 70% total cocoa content and with an ingredients list that consists of ‘cocoa beans, sugar’ and that are processed entirely in a melangeur” are   not   same recipe   if   the beans   are from different origins . The question is, “Are cocoa beans from Nicaragua the same ingredient as cocoa beans from Colombia?” Probably.   But maybe not .

It’s not all that hard to get to a count of 100,000 if your interpretation of “recipe” is broad – the approach suggested in 1) above. Assuming only 50gr bars are being molded, 100,000, 70% bars comes out to be less than 5MT of beans.

However, if you do have to put a nutrition facts panel on the label, with the broad interpretation in 1) you can use   the same   nutrition facts panel for every product that has a similar preparation method and the same ingredients. This reduces the cost of compliance significantly.

Because of the ambiguity of the regulations it   is possible to argue that beans of different origins are different ingredients; they have different fat levels and macronutrient contents. (It might also be possible to claim that using a melangeur and using a ball mill and roll mill are different preparation methods within the meaning of the regulations.)

For every product with a different recipe – and this does mean inclusions or flavorings and could include equipment/method – a labeling exemption could be claimed. This is the narrow interpretation in 2) above, which could, theoretically, be used to keep product counts below 100,000.

The narrow interpretation in 2) has not been tested that I know of, and the distinction is likely never to be something that would be of interest to the FDA.

However, as was pointed out, it is likely that a regulator or inspector would consider any liquor to be the same ingredient as long as the macronutrient content was within allowable limits–tending toward the interpretation in 1). That said, with adequate record keeping in place to document segregation of ingredients and processes, it might be possible to successfully argue the case that liquors made with beans from different origins were different ingredients. Ask a lawyer before going down this path.

Top Line Summary and Conclusions

Again, I am not a lawyer so please do not rely on this interpretation should you be inspected. Consult a lawyer before you decide what, or what not, to do.

1. If your company is eligible for the labeling exemption you must apply for it to be in compliance with the NLEA.
2. Your company  must   file for an exemption   for each year and for each product   for which you want to claim the exemption,   unless   you have fewer than 10 FTE employees and sell fewer than 10,000 units of a product.
3. If your company has more than 10 FTE employees, is making more than 10,000 and fewer than 100,000 units of any product in a twelve-month period, and has fewer than 100 FTE employees and is not making health or nutrition/nutrient claims on the label,  the products that are manufactured in under 100,000 unit quantities are eligible for a labeling exemption.
   
4. If your company has fewer than 100 FTE employees, you can have a mix of products that do and do not qualify for the exemption. However, your company  must   file for the labeling exemption   each year and for each product that qualifies for the exemption .
   

Going back to the original question: assuming the Mast Bros have fewer than 100 FTE employees, it is possible for them to claim a small business labeling exemption for many, if not all, products they make. It all depends on how they count to 100,000.

That said, it is my sincere hope that every chocolate maker will see the wisdom in providing this information somewhere, if not on the label then on their web site, in the box when shipping direct, and to their retailers. I don’t know where the cut-off should be - $500k in annual sales? – but I’d like to see small makers adopt the business discipline and responsibility and put nutrition facts panels on their labels even if they are not required to by law.

Notes

On a related labeling point, if you are using cocoa beans with less than 50% fat you cannot legally call your product chocolate as the regulations for cocoa liquor require 50% minimum fat content. From my reading (again, IANAL), even if you added cocoa butter to get to the 50% minimum, your chocolate would still not legally qualify as chocolate because the definition applies to the liquor. This is not something a small maker is likely to ever get called on, it’s just something to be aware of. (CFR 21 Sub-part B §163.111, Chocolate liquor.)

In addition to the nutrition label, products may display certain nutrition information or health claims on packaging. Health claims are only allowed by the FDA for "eight diet and health relationships based on proven scientific evidence", including: calcium and osteoporosis, fiber-containing grain products, fruits and vegetables and cancer, fruits, vegetables, and grain products that contain fiber—particularly soluble fiber—and the risk of coronary heart disease, fat and cancer, saturated fat and cholesterol and coronary heart disease, sodium and hypertension, and folate and neural tube defects.

Paleo food labels and advertisements are no exception to these rules. Companies that advertise the health benefits of Paleo foods must ensure their claims are not misleading to consumers and any claims they make are backed by appropriate scientific support. At the same time, companies should beware of making negative claims about the potential “detriments” of non-Paleo foods (e.g., that dairy, soy or corn products are unhealthy), which could attract unwanted negative attention or legal action from those industries. [Note: By extension, claims made for raw would be subject to this logic.]

Sources

• http://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/LabelingNutrition/ucm053857.htm
• http://www.fda.gov/ICECI/Inspections/InspectionGuides/ucm074948.htm
• https://www.accessdata.fda.gov/scripts/nle/client/report/
• https://en.wikipedia.org/wiki/Nutrition_Labeling_and_Education_Act_of_1990
• https://en.wikipedia.org/wiki/Nutrition_facts_label
• http://www.foodsafetymagazine.com/enewsletter/labeling-of-health-and-nutrition-claims/
• https://www.law360.com/articles/639623/is-paleo-the-next-battleground-in-food-litigation

Introduction

I first started attending high tech industry trade shows in 1983, and in the intervening 30+ years I have probably attended - or been a presenter and/or exhibitor at - well over 200 trade shows and festivals of all kinds in the US and Europe, ranging from small local and regional chocolate festivals such as the NW Chocolate Festival to the NCGA (National Computer Graphics Association,, SIGGRAPH (Special Interest Group for Graphics of the Association for Computing Machinery), Photokina, MILIA (International Multimedia Market), NAB (National Association of Broadcasters), Salons du Chocolat, CHOCOA, FFS (Fancy Food Show), FCIA (Fine Chocolate Industry Association), the National and World Pastry Team Chamionships/World Pastry Forum, Expo East, NY Restaurant Association, IBIE (International Baking Industry Exhibition), and many more.

Although there are several different industries involved in the list of festivals and shows above, as a participant in these shows and events one of my primary goals in taking part has always been to gain perspective by seeing changes over time. There’s always something new and noteworthy to find at each show, but is it a fad or a genuine trend that needs to be taken seriously? It gets easier, I find, to make these kinds of evaluations the more experience I have. I get to see different aspects of the same industry, so I can look at new product introductions from different points of view.

However, it is possible to over-attend. When this happens, all you ever end up seeing is incremental change, if even that. “New” and “noteworthy” end of being tied to minor “innovations” such as new packaging, and really anything substantive.

All that introduction aside, I have been attending FFSs since the summer of 2001. I vividly remember meeting Frederick Schilling at that show - also the first FFS for Dagoba. While I believe I have been to maybe all but one or two Summer FFS since 2001, I only started attending the Winter FFS regularly since 2010 or so. Over that time I have seen flavor fads and trends and companies come and go.

Follwing is a sampling of what stood out at this year’s Winter FFS. As a chocolate professional who is making chocolate or confections, some of my observations and fads, trends, and flavors may spark new product ideas for you to explore. I hope so!

Diversity: The Winter FFS in San Francisco has a different mix of exhibitors than does the Summer FFS in New York. While there are large country pavilions at both shows, there are more and they are bigger at the Summer Show, which also includes many more US state-sponsored areas.

Cheese: While cheese has always been a large part of both FFSs, it’s always seemed to me to occupy more space at the Winter FFS and this year there was so much cheese you could have called it the FCS+ (Fancy Cheese Show plus other stuff) and not been far off. Cheese offerings ranged from very small producers to very large ones and encompassed so many different varieties and examples of each that I found it to be literally overwhelming (as well as very tasty).

Influence: This does lead into a very interesting fact about the center of gravity that both the Winter and Summer FFS have become. Because of the sheer number of people who attend, the FFS has accumulated a number of satellite festivals deliberately scheduled to coincide with the FFS. At the Winter FFS these include the Good Food Awards, the Fine Chocolate Industry Association, and the Cheese Monger Invitational. Two of these three are also scheduled around the Summer FFS.

Superfoods: As a category, superfoods are less important at the FFS than they are at Expos East and West. Exhibitors in this category seemed to me to be down from prior shows, but there were a couple of entries for a “new” (at least to this show) superfood: morninga. As this was my first sighting, and the number of exhibitors was small, it remains to be seen if this was just a blip or if it’s the start of a fad that could turn into a sustainable trend. This sector of the market relies on the introduction of new products to keep it interesting so I will be on the lookout for moringa at the Summer FFS.

Confections: A number of entries in the gourmet marshmallow category made themselves immediately visible. I firmly believe that the standard grocery store marshmallow only has a place for campfire s’mores and as a binder for crisped rice treats. A well-made marshmallow is a real treat, and the ones I tasted were all well made. But marshmallows always seem to me to be an afterthought and a category that seems like it would be price sensitive. If gourmet marshmallows survive and thrive I think it will be because of the following trend:

Not as bad for you: There is a growing number of companies that are selling sugar candy with advertising and marketing that includes “all natural” and “organic”. But it’s still mostly sugar and therefore not good for you  … but you can feel good giving it to your kids or eating it yourself because it’s not as bad for you. No HFCS, no GMOs, vegan (or suitable for vegetarians) gluten free, no artificial flavors or preservatives, only they are still 100% empty calories with very little to no actual nutritional value. This is an actual trend.

Another health-related claim that caught my eye was probiotics. Normally associated with fermented foods such as yogurt, kefir, sauerkraut, and others, there is now a move to add probiotics and prebiotics to foods that normally don’t have them. This includes chocolate. One company markets theirs added-probiotic chocolate as “The Planet’s Best Chocolate” and the phrase is not trademarked. A bold claim and as someone who has eaten a lot of chocolate - professionally - over the past 20 years, I can say that these do not come close to being the best on the planet. Maybe it depends on what they mean by best: what the meaning of “is, is.” Best tasting? Healthiest? Most environmentally sustainable? All? A hyperbolic claim that is mostly objectively unprovable. They also claim that their 72% cocoa, which is “always smooth, never bitter” to 28 years to develop. They will likely be successful, despite the fact that it’s objectively not the best chocolate on the planet.

Finally, on this topic, there were a lot fewer stands promoting raw products. At least within the specialty foods markets served by the FFS, raw is past its prime. Likely those companies are now congregating over at Expos East and West.

Reimagining maple:  Maple is a very highly regarded sweetener. So highly regarded that Canada maintains a strategic reserve to help manage price volatility. It is also highly regarded among those who are concerned about the types of sugars they consume and has a reputation for being “better” and  “cleaner” than other sweeteners. Plus, it is vegan. However, maple is also, apparently, boring. There were many maple companies offering up flavored maple syrups, some of which sounded quite un-tasty, thank you very much. I don’t know what to make of this, expect to speculate at the root cause, which is slowing sales. Flavored maples, which are easy to make at home (I have been infusing fresh ginger into maple syrup for years), are a way to add SKUs and attract new consumers. This is an adoption of a common strategy in other areas: flavored oils and vinegars – a strategy that is being enthusiastically adopted in …

Jerky: The jerky category has been growing wildly (at least in terms of the number of companies in the category) for years. At first, it was okay to have three varieties: plain, peppered, and teriyaki. When growth started flatlining, there were two areas of extension; adding in meats other than beef, and downsizing and claiming to be “craft” - whatever that means when you’re processing tons and tons of product a week. A couple of years ago we saw the first moves into ethnic jerky, specifically biltong from South Africa, and Winter FFS saw the introduction of others, including Singaporean street jerky. Attendees at Winter FFS were also subjected to an explosion of new flavors, including fruit-flavored jerkies, new types of peppers - if I recall correctly even a scorpion pepper-flavored jerky - and more. My guess is that we are going to see a lot more “innovation” in this space over the next six months. Chocolate-flavored jerky, anyone?

Kombucha and cold brew: Lots more kombucha and cold brew coffee concentrates, and also the introduction of new ways to serve them: taps such as those used for beers. For several years it’s been possible to self-fill growlers of kombucha and my guess is that this is about to go mainstream. Self-serve cold-brew is not far behind. (Though, I gotta admit, I don’t see how self-serve cold brew can compete with a barista-assembled Draft Latte from La Colombe.)

Bone broth: The science behind the benefits and efficacy of consuming bone broth is shaky. So, while the companies offering it seemed to appear from nowhere, I don’t see this as anything more than a fad. Of course, being faddish never stopped anything from being wildly successful so I could be entirely wrong here - and shaky science behind a food claim has never deterred anybody, ever, as near as I can tell.

Artisan: The word artisan has been so overused it’s become virtually meaningless. While there are some formal definitions for artisan (fin France, in order for a boulangerie to advertise its bread as “artisan” the dough must be mixed, proofed, and baked on premises), there is no guidance here in the US for its use. Even though the term has lost currency, companies are not abandoning it, and are even doubling-down with compound phrases such as “fine artisan” and “high-end artisan” and even “elevated artisan.” These are nonsensical to me and do not solve the problem. Part of my issue with these is that no one would claim to make the inverse claim: my product is low-end artisan, or my product is so-so artisan. No one ever claims to use the world’s second-best chocolate. Only the best. World’s finest/freshest - insert adjective here - no one ever claims to use or make anything but the best. Even when the ingredients list is rife with industrially-made replacement ingredients, the maker will try to search for some “best’ adjective.

But, what about chocolate? Nothing new and interesting? Not much, actually. Part of this is that it’s hard to really innovate in chocolate, and I don’t think that adding probiotics to chocolate is interesting, at least not to me. Still yet another raw or semi-raw chocolate is not new or interesting. Another from-the-bean company offering still yet another two-ingredient chocolate is not going to move the needle. There was a lot of beautiful new branding and packaging to admire, and the examples I saw will no doubt help sales, but I don’t know that that as newsworthy in this context.

At the FCIA meeting on Saturday, it was revealed that - at least among consumers who identify as fine chocolate lovers - that health was not a strong motivating factor in their purchasing decisions. More recently, however, research firm Euromonitor announced that health-related claims are going to be a major factor in growth - at least in the mass market. It remains to be seen what the lasting impact will be in the specialty market.

But I did run across two products with chocolate that caught my eye.

The first was a result of some out of the box thinking and involved using nori (the pressed, dried, seaweed paper that is used for sushi and has recently caught fire as a snack), as the crunchy element in confection. A thin layer of (flavored) chocolate is sandwiched between two sheets of nori. The nori not only provides the crunch, it imparts a salty/umami character to the product that is really quite interesting. I have no idea if this will take off, but I liked the products I tasted - a lot - and I think it’s a great example of what innovation can and should look like in chocolate.

The second was a straight-up, no apologies asked for appeal to childhood: Bond Bar’s Bond Bites Caramel S’Mores. If these were available by the tray, uncut, I would order one. And maybe not share with anyone. The only possible way to make them better would be to add bacon to the caramel.

The next show I am planning to attend is the New York Restaurant Show in March, so expect another report on what I saw on the show floor.

Jim -

Thanks for the clarification.

Intuitively, I think that the Aw would only take into account the water in the spirit you're adding.

Ports are around 20% ABV, so if your recipe calls for 50gr of port in a 1kg recipe, that's 10gr of alcohol in 1000gr or 1% alcohol by weight. You've also added 40ml of water, but given the extended contact with alcohol, it should be free of live microorganisms.

However, given the Stilton (which is infected with mold spores) and cream in the recipe, the comparatively small amount of alcohol from the port is probably not going to affect shelf life significantly.

I would look to other techniques to reduce Aw and look to pasteurize the cream and cheese to kill as many live microorganisms as possible.

I strongly recommend that you get a copy of Peter Greweling's book Chocolates and Confections: Formula, Theory, and Technique if you don't already have it.

What kind of alcohol are you using, and at what proof? You can buy Everclear at 190 proof (95% alcohol, 5% water). An 80 proof spirit is 60% water. Then there is the question of how much alcohol is in your recipe.

Many states regulate the maximum alcohol content - in Massachusetts it was 1% last I looked. Some states require that buyers be 21+.

Even with a lot more info, I don't see a simple way to arrive at an answer.

Sebastian:

If you are willing to share your Russian Imperial Stout I am there with chocolates to pair and share!

Reporting back after my Valentine's Day chocolate/beer pairing at Burp Castle, NYC.

It is always fun to work up chocolate and beer pairings. I find it a lot easier to create happy marriages between chocolate and beers than with wines. Some of it is due to the fact that I find beer has a much wider variety of textures and structures than are found in wine - there is something comfortingly compatible in the combination of the soft creamy bubble structure of a classic British Pale Ale and a milk chocolate that, in my experience, has no counterpart in still and sparkling wine, with the possible exception of the sparkling wine offerings from Rumball (Australia).

Beers and chocolates are both made with ingredients that are roasted, and I definitely believe that that is one of the reasons for the harmony between the two.

Still - there is huge variability in beer and I purchased the chocolate without knowing exactly that the beer lineup was going to be. So my approach in the store ( 2Beans  at 100 Park Ave) was to think about styles of beers that might be on tap and make generalized selections. Knowing that Burp Castle is a Belgian beer bar I could be pretty confident that there would be no big American-style over the top hoppy IPAs. Ales, sweet lambics, sours, ciders, tripels, quads, and other styles. A lot of territory to cover — but I am up to the task! Because I had not tried all of the chocolates and was not familiar with all of the beers I showed up about an hour early to taste everything.

Here’s where things settled out:

Liefman Fruitesse (4.2% ABV - alcohol by volume)
Köstritzer Black Lager (5% ABV)
TCHO 53% milk

These two beers are about as far apart as it’s possible to get and yet the TCHO 53% milk goes well with both.

I’ve paired milk chocolate with fruity lambics before (Lindeman’s Faro might well be my all-time fave in this category) and the result is strongly reminiscent of a chocolate-covered whatever the fruit is. With the Lindeman Faro - which is made with Belgian candy sugar and finishes with tart Granny Smith apple, the result is just like a milk chocolate-covered caramel apple. With the Fruitesse what you get is a mix of chocolate-covered cherry/strawberry yummmm.

The Köstritzer Black Lager is dark as a stout but is not heavy with the fragrance of chocolate malt. Instead it comes across more like a soft English Pale (think Brooklyn Brewery’s Pennant Ale) with a very soft, creamy, bubble structure. The fudgy character of the chocolate plays with the yeasty notes of the lager very nicely.

Wells Bombardier ESB (5.2% ABV)
TCHO 39% milk

Staying with milk chocolate for a moment. I picked the two TCHOs because of the difference in percentage. 2Beans had many other milk chocolates but I was curious how these two different offerings from the same company would fare. The 39% was not bold enough to hold its own against either the Liefman or Köstritzer but presented a nice balance with the ESB, which despite the initials (ESB = Extra Special Bitter) is not at all bitter, with an official IBU (International Bitterness Units) rating of 0. It’s thinner-bodied than the Köstritzer, too, and there is a yeasty breadiness that balances nicely with the distinct caramel notes of the chocolate.

Radeberger Pils (4.5% ABV)
La Guillotine Belgian Blonde (8.5% ABV)
Milk Boy 60% dark w/ pine essence
Pump Street Bakery 60% Rye Crumb/Milk/Sea Salt (Ecuador, Hacienda Limon)

I selected these two chocolates on the off chance that there might be beers with a bitter edge to them, as well as to see how they worked with some higher–alcohol choices I knew would be on tap. I also chose Pump Street because. Chris Brennan. And - rye bread crumbs as an inclusion, though I could have gone with the sourdough which I am definitely going to try soon - with a sour. The Radeberger, though it is a Pilsener, is a little on the strong side for a Pilsener (to me) and does have a bitter edge to it. The resinous quality of the pine and the rye crumbs brought out that aspect of the Radeberger in a nice way, and both stood up to - and complemented - the alcohol content of the La Guillotine.

Allagash White (5.1% ABV)
Bonnat 75% Mexique Grijalva

In addition to what I bought at 2Beans I brought some bars from my personal stash - and one of those was this *very* limited edition bar made from beans from a grower I worked with on my #CacaoMEX project down in Tabasco, MX, last year. One bag was shipped to Bonnat in Voiron to turn into chocolate that we then debuted at the Salon du Chocolat in Paris last October. While there is room for improvement in the fermentation of the beans, the chocolate has a depth and richness of flavors, including some soft spice and raisin that are not typical of the region. The Allagash is a hefeweizen made in Maine, and its soft structure complemented the buttery texture that is classic Bonnat. And, because hefeweizens are strongly associated with orange (slices are often used for garnish), the spice and raisin aspect of the chocolate made the combination quite tasty.

Tripel Karmeliet (8.5% ABV)
Southern Tier Creme Brulée Stout (10% ABV)
Harper Macaw 73% bourbon barrel aged (Brasil, vale do Juliana)

Both of these are big beers and while I don’t generally believe that going big with big is the best approach, in this case the bourbon notes in the chocolate are what made these combinations work - the chocolate simply became a natural extension of the beers.

Ommegang 3 Philosophers Quad (9.7% ABV)
Pralus 80% Fortissima

This is another case where pitting big against big really worked - assuming, of course, that you like that sort of thing. The Fortissima is a blend and comes across as more intense than a lot of 80%s in part because of the heavy roasts that Pralus is known for.

Rodenbach Grand Cru Barrel-Aged Sour (6% ABV)
Aspall Dry Cider (6.8% ABV)
Cacao Sampaka white w/matcha and lemon

This is an example of just going for it - not just thinking outside of the box, but forgetting what boxes look like. Not many people I know would think of bringing a white chocolate to a beer pairing but as far as I am concerned nothing is off limits and I was sorely tempted to also bring the Rococo white/cardamom bar. In this case the sweetness of the chocolate is a foil to the sourness of the Rodenbach and the dryness of the Aspall (apple) cider. The beers make the chocolate less sweet and the chocolate reduces the dryness of the cider and the sourness of the Rodenbach, which is a one-third/two-thirds mix of new and old Flanders Red ales - there is no fruit used but there is a fruity tang to the beer. And that’s where the matcha and lemon kick in for both the sour and the cider … the vegetal/floral character of the matcha and the citric tartness of the lemon add dimension and complexity all the way around.

And that, my friends, is how I spent my Valentine’s Day, exploring my love for beer and chocolate, and sharing it with beer and chocolate lovers. My thanks to 2Beans for supporting me in this tasting.

 BurpCastleTastingBeerSelection.jpg - 284KB

Mitch -  

Chocosphere is a great recommendation. Ask them for the closest equivalent as start.

Because I have worked with a Guittard distributor I can tell you that make maybe two dozen different darks and a dozen milks. Many are packaged for food service applications that you won't find generally available.

Where are you located? I would contact Guittard and ask for their local sales rep. You can tell them what you want and they can recommend something and they will provide samples. If your needs are large enough you may be able to lower your costs.

:: Clay

Compatible Technology is a non-profit organization I have wanted to support since I first learned of them and I think their grinder could be a real good option for many startup makers. It's inexpensive - closer to a Corona mill than an Old Tyme peanut butter grinder even when motorized - and there is an option to buy one and donate one.

If you try this grinder ... please let us know how it works out!

Peter - Good tip as a way to perform the kill step after winnowing.

David:

Where are you located? (Please update your profile to include your two-letter country code to make it easier for us to find out - helpful when answering questions.)

Tonka beans (and extracts) are not allowed  as a food ingredient in the US since 1954 because they contain coumarin.

There are many other common foods that contain coumarin whose consumption is not prohibited, but if you were to list tonka beans as an ingredient you would be breaking the law.

That said, they appear to be easily available on Amazon.

Marck -

How would one get in touch with the chefs you mention ... and how would a chocolate maker looking to use CinnaPepper get hold of samples to create recipes?

Chris -

"[...] the temperatures involved in the distillation process, coupled with the alcohol of the finished product, are likely to kill any bacterial pathogens that might be present on the shell."

Does this still hold true now that I've clarified that the product would be a rum infused with cacao and not a spirit distilled from cacao? 

Temperature is only a consideration if you re-distill after maceration. Alcohol levels still apply.

Also, does this also hold true for the brewing of beer? Figured it's worth asking since the alcohol content is significantly lower.

It depends on how you get the cocoa flavor into the beer.

You could do it by making the cocoa nib a part of the mash bill (whole beans would probably not work). In which case, the boil would kill everything. However, there are issues with respect to fat content that need to be taken into consideration if you are going to boil nib. This is something that a competent brewer should know about.

If you are getting the flavor into the beer using the technique known as dry-hopping (again, whole beans will not work here), then you are relying totally on the alcohol to take care of any microbial contamination unless there is a post-winnow sterilization step. I don't know the efficacy of a 3.2% level of alcohol relative to an 8%+ level of alcohol. You'd have to test.

Chris -

Thanks for the clarifications. There is history of infusing an already-produced rum or whiskey using cocoa. This is one of the things Cacao Prieto intended on doing and they purchased a huge macerating tanks exclusively for this purpose. They were planning to distill the resultant liquid, but my guess is that a simple filtration process prior to bottling is all that is necessary unless you suspect microbial contamination from the cocoa.

My experience is that it's more efficient to use nib (over whole beans with shell) because of the increased surface area available. Nib will absorb the alcohol much, much, faster than a whole bean can - and that's reason enough to go with nib. Another reason is that it's going to be easier to remove excess liquid from a mass of nib than it will be from a mass of whole cocoa bean and shell. (You do need to find something to do with the paste from the nib.)

If you want to try something in the kitchen, get an ISI cream whipper and NO2 cartridges. Warm the container with hot water and then empty - no need to dry. Measure in some alcohol (sweeter - relatively speaking - rums and bourbons give better results than less-sweet spirits such as vodkas and many whiskies in my experience; gins are mostly a no-go), and measure in some refreshed nib (warmed up in an oven). Pressurize the container and shake. Wait 3-5 minutes before carefully releasing the pressure. You will have cocoa-flavored spirits -- and you can control the level of cocoa flavor by experimenting with the ratio of nib/alcohol, type of alcohol, other ingredients, and time spent macerating under pressure.

Chris:

First off, if you make a distillate from cocoa beans it cannot legally be called either rum or whiskey. There are very strict rules laid down by the TTB (The Alcohol and Tobacco Trade and Tax Bureau) with respect to recipes and labeling. For example, to be a rum, the product must be made from sugar or a sugar by-product (e.g., molasses).

I know this because of a) the work I did to help Cacao Prieto (now Widow Jane) gets its federal and NY State permits; and b) the work I did with New World Spirits to get a new TTB classification (the first in about 150 years) for Solbeso, which is distilled from the juice of fresh cacao pulp.

Whatever you make from distilling cocoa you cannot call it - or label it or hint at in advertising or marketing - either rum or whiskey because it does not meet the definition of those sprits  (.PDF) . There is an "other" category called DSS (Distilled Spirits Specialty) and this is where a product made from cocoa beans (whole or nib, roasted or unroasted) would fit. From experience, if you don't have A LOT of money (hundreds of thousands per market )  and time, it's really hard to launch a new spirit that does not fit into a mainstream category.

If you plan to get involved in this project (or any distilling project) I suggest that you do your homework and learn about distilling processes and the licensing process with the TTB. The first place I would start is the TTB web site because there are a lot of great resources there.

From my personal, first-hand, experience, the temperatures involved in the distillation process, coupled with the alcohol of the finished product, are likely to kill any bacterial pathogens that might be present on the shell. And, I don't think it is going to be too difficult to overwhelm whatever viable yeasts remain on the shell, even if you do end up using whole beans. There's more I could say about process and recipes, but I have an NDA with the producers of Solbeso.

My primary concern with using whole beans - as you rightfully point out - would be with heavy metal and inorganic chemicals that might be present in the shell - as these might make it through to end of the distillation process. Testing must be done to ensure that they are not present, and you would be advised to do this both before and after distillation, starting with test batches well before you start even thinking about the process with the TTB as you are going to have to provide certificates of analysis in order to get permits to sell.

Starting from nib obviates many potential difficulties, but does not obviate the need for proper (and ongoing) testing. There are simple batch sterilization methods that can be applied to nib that don't involve heat/steam if that's a concern.

As for the Mast Bros. From a strict marketing perspective it makes sense to try to associate with their famous brand. However, from what I have heard of their history of partnering there is a risk that they may try to take credit for the idea, should it benefit their brand. I would be very careful when approaching them and make sure you have a very good IP lawyer. From a raw materials perspective there is nothing special about the cocoa they can provide. There are any number of alternative suppliers who can provide the raw inputs you are looking for (and I would actively argue against whole beans) on a large scale, at much more attractive prices.

There are other products that can be made from alcohol and cocoa, with different starting points. There may be areas I can help with that would not violate my confidentiality agreements with NWS/Solbeso - and I am happy to help (consult) where I can.

Thanks for the link. This appears to be a two-part machine consisting of an enrober belt and what is sometimes called a "truffle tray." To use, it also requires a Selmi tempering machine ... I believe a machine with a minimum of a 25kg working bowl is required.

Can you post a link to the page on the Selmi web site for the machine you are referring to?

Right off, I would look at how much oil you are adding as even small amounts can affect the development of the proper crystal structure - depending on the type of fat.

If this is the case, you'll want to start playing with time and temperature. The dosed chocolate may need to get colder at the bottom of the curve than the un-dosed chocolate and you might not want to warm it up as much. 

I might also add the oil in after the cooling cycle has started, assuming that there is enough time to mix the oil in completely so dosage is consistent throughout the chocolate.

Likely it's a combination of time, temperature, and when you add the oil. Less to do with the tempering machine itself. However, with 200lb batches, experimentation takes a while and could get expensive.

There is no need to post the same question in two different forums. I am closing this one down and linking to the other post .

Crio Bru is made from ground roasted cocoa beans. No shell involved.

Here is a link to some information on the differences.

It is true that if you get 3-phase now you will either have to make sure that the place you move to has 3-phase installed or you get a phase converter installed ... you might be able to negotiate that into the lease (I would).

The 3-phase machine will be more energy efficient when compared with a single-phase machine, and because of the way they are built, 3-phase motors are likely to be more robust than single-phase motors. A 3-phase machine could also potentially be less expensive than a single-phase machine.

This assumes that the location you are in has 3-phase 220V power installed.

If it does (and you have the space in your panel) - it always makes sense to go for the 3-phase machine. If you do not have 3-phase installed, it is almost always cheaper to go with a single-phase machine than to either a) get 3-phase installed, or b) get a rotary phase converter.

Getting 3-phase installed can cost tens of thousands of dollars and take months and months and is often (in my experience) up to the whim of the local electric company. While it might be nice to use a static phase converter, because of the changing reactive loads in the tempering machine (compressor, heaters, stop/start of motors), a static phase converter is not the best choice. Rotary phase converters can easily cost well over $1000 (depending on the loads in the tempering machine) which is lots of kilowatt hours of electricity. So - you have to weigh the lifetime savings cost against the CapEx of the phase converter.

Note that you do have to let your equipment supplier know in advance which you need - as the power cord used to connect to the supply will be different. The cord in a 3-phase machine will have four wires, whereas a single-phase machine will have just three wires, and you need to wire the plug, socket, and panel accordingly. Because code.

You can always connect a single-phase machine to a 3-phase panel, the reverse is not true.

The stated capacity of most of these wet-mill grinders is the volume of the bowl.

The batch capacity (in kg) is typically 50% of the bowl volume. 20L bowl is ~10kg of chocolate.

The manual for the scale does mention that there is auto-shutoff for the display, but not the scale. I would contact Ohaus directly to find out for sure. There may be a difference when it's on battery as opposed to being plugged in. BTW, the scale I linked to is well liked on Amazon. (You could also ask the question of the users who reviewed the scale on Amazon about the auto-shutoff.)

I did learn that it's possible to purchase a beam scale with a tare function but I cannot find one with a capacity of over 2kg.

Beth -

The real question here is what accuracy do you need at the low end?

A scale with a max range of 15kg might only have a resolution of 5gr. That would be okay for measuring 10kg of couverture, but might not be okay for measuring some other ingredients you might add. So you would need to consider a separate scale for measuring small amounts.

An inexpensive digital "pocket" scales can measure up to a kilo at .1gr resolution for under $20 (but don't forget to order a calibration weight if you buy one of these). It's going to be cheaper to buy two scales than to get a scale that can weigh out 15kg with a resolution of .1gr. A 15kg scale with a resolution of 2gr can have a discounted cost of about ~US$160 before shipping. A 15kg scale with a resolution of .1gr will cost at least US$100 more.

While you don't need a washdown scale, there are scales in the ~$160 price range that are NSF rated.

I routinely use the Affordable Scales web site to locate scales for specific uses ... you could do this and then find a supplier in Canada if they don't ship.

Tony:

I don't have a particular source in mind, I was just asking for clarification for others who might read and want to respond.

Still need to know quantities involved. A broker such as Meridian in Oregon or Atlantic/Ecom in NY could easily supply you with Ecuador that could meet your quality requirements (not knowing what they are).

Java/Bali is a bit harder, though I would inquire through the brokers to see if they have anything. I know Big Tree farms sells nib, not sure if they are also selling beans.

Andy -

There are some interesting fed gov't documents you can read:

Natural and Biological Pesticides

Take a look at the links near the bottom for more. Note that whatever gets used needs to be odor-free or the odor will be absorbed by the fat in the beans. 

About GrainPro bags:

"[ They are ] made from multilayer recyclable polyethylene plastic (PE) with a proprietary barrier layer with sufficiently low permeability to prevent the exchange of air and the absorption of moisture. [They are] designed to be used multiple times.

[They] effectively stop aflatoxin growth, eliminate infestation embedded with the commodities and prevents the penetration by [insects] in the commodity without the use of harmful chemicals."

When it comes to live insects and larvae, the bags increase the CO2 level within, effectively suffocating them. However, they are less effective against eggs so if you remove the beans from the bags the eggs can hatch.

Why not use GrainPro bags for long-term storage of cocoa? I know people who have used them for long-term (> 3 months) and they told me that some trained tasters can detect a plastic-y odor from the bags. Because the GrainPro bags are used inside the jute bags (to help preserve barrier integrity), they are comparatively expensive.

Plus, there is also the possibility (which some have noticed with Grainpro bags) of the beans picking up plastic-y odor if stored in the bags for extended periods of time.

Tony:

What kind of quantities are you looking for?

Do they have to be in the US or are you willing to import?

:: Clay

Beth -

Every machine in your workshop should have some sort of preventive maintenance schedule. What that schedule looks like, and what it entails, depends on what kinds of components the machine has. For example, in a machine with a compressor for cooling (refrigerator, some tempering machines), you will want to check the refrigerant level on at least an annual basis and vacuum the heat exchanger (radiator) on at least a quarterly basis if not more often. I recommend scheduling the maintenance 3-4 weeks before heading into a busy production period. August for Christmas, early-January for Valentine's Day, etc. This means you have time to address issues before downtime becomes critical. I have one customer who schedules preventive maintenance on a monthly basis, taking all of his machines out of production over a weekend. They produce over 10,000 bars/day and there has never been an interruption during a critical production period.

Motors something to look closely at and clean, as are critical wear parts such as bearings and seals.

DO NOT overfill the machine. The stated capacity is the entire bowl. The actual capacity is under the axles when working with chocolate. Overfilling will increase processing times, in part because mixing is less efficient.

There is no typical order for adding ingredients - except that the order and timing of adding and the length of processing has an effect on the flavor. Both sugar and cocoa butter absorb aroma and flavor, so adding them in early in the process makes it more difficult to get rid of undesirable aromas and flavors. It's worth experimenting to see what your results are and what you like. But, given the small machine, I would put work just the liquor until it was very fluid and then add the sugar in in one-third or one-fourth portions and give each portion time to grind before adding the next. If you add the chocolate in all at once you're likely to cool the chocolate down too much and the wheels will seize. And yes, I know this because it has happened to me.

Powdered sugar, when added to chocolate, will immediately suck up any moisture in the chocolate and make the chocolate very thick. In addition, it changes the taste of the chocolate, in part because of the way the sugar absorbs aroma and flavor, which are different than with large-crystal sugar. So, that's something to consider.

Jim:

You can get away with up-converting 120V to 220V for this application -- I did not know that this would be put to use in a home setting. The Clima is 220V 3-phase, so not something you'd put into a residential setting.

An electronic converter that is designed for use with appliances will be fine. I have a couple of options I could recommend in the ~$100 range.

Jim - no trouble as I am in fairly regular contact with the people at Angel Refrigeration (Everlasting does not sell retail so it is necessary to go through a dealer and there is no US dealer). I don't think these are available in 120V, but I can get in 220V single-phase.

Jim -

Angel Refrigeration in the UK represents Everlasting and other brands, and I am their agent in the US. Everlasting makes several temperature and humidity-controlled cabinets specifically for chocolate.

Here is a link to Everlasting chocolate refrigeration products on the Angel Refrigeration web site. The option I recommend most is not listed, but it's a two-door version of the Choc71 and Choc101 solid-door models. The two doors are arranged one over the other (not side by side), so you are only opening half the fridge at a time. The 71 holds Euro-sized sheet pans (which you can order through Angel). The 101 holds US-sized sheet pans through the inclusion of racks along the sides. If you are interested I can get you prices.

:: Clay

The Clima is good option when you need to balance throughput with available space. The Clima is not cheap when compared with some DIY solutions, but it requires very little space (comparatively) and it's easy to put molds onto the Clima input belt without having to move from the depositor so in that respect it's quite labor efficient. At roughly 3.5 molds/minute (timing can be adjusted to increase/decrease time in the tunnel based on cavity thickness) the cooling time is about 13 minutes. We have success cooling 100gr bars in molds with 3 cavities at this speed.

You can find a downloadable US/60Hz catalog page here . Pricing may change in January, so prices are guideline only (as it's December 30 and there's no time to place an order before Jan 1).

The major change I've seen is that the US$ is now stronger than the €uro. Otherwise, prices are fairly stable. Ocean shipping costs can vary depending on the cost of fuel and differences in cost structures between shipping companies.

Christopher:

Welcome to TheChocolateLife! While I hope that ChocolateLife members will share with you directly, I also encourage you to ask you to ask questions as they arise. The greater the volume of postings the greater the likelihood that people will respond.

You might also consider a regular series of blog posts to document and share your progress. I know we'd all like to hear more ... there are many, many members of TheChocolateLife in India.

:: Clay

Posted in the last 24 hours on Facebook. It's a start. I can only hope that Georg will personally visit everyone else in TRS that he labeled "unconfirmed." In the case of Pacari, I believe he relied in part on "unconfirmed" gossip from unreliable sources and did actually do the necessary work to determine whether the gossip was true.

Suzanne -

Are you here in the US? Some sources from Europe might not be good for you.