About a year ago, a "citizen" petition was sent to the FDA, asking if chocolate manufacturers could replace cocoa butter in chocolate with "cocoa butter replacements" or "cocoa butter substitutes," while still calling the misbegotten product "chocolate." (I guess you can tell where I stand on that issue, and many of you have your own opinion.)
Believe it or not, despite the United States' bad reputation for chocolate, we're actually ahead of the European Union on this one. The EU version of this Standards of Identity (the documents that specify what ingredients can or cannot be in food, and what you can call them) allows manufacturers to substitute up to 5% of the cocoa butter in chocolate and still call the resultant—whatever it is but it's not chocolate as far as I am concerned—"chocolate."
That does not keep manufacturers from replacing the cocoa butter with other fats; they just can't call them chocolate anymore.
Hershey, for example, makes something called Special Dark® Chocolate. If you look at the label, you'll notice it's trademarked. Elsewhere on the label, there's the phrase mildly sweet chocolate, which means the chocolate conforms to the FDA Standard of Identity for "sweet chocolate." A look at the ingredients reveals the presence of milk fat and other dairy-derived ingredients, which enhance shelf life and contribute to the pasty texture.
Hershey has taken the next step in the process, replacing the cocoa butter in some of its chocolate with far less expensive vegetable oil. Of course, they can no longer call it chocolate or even milk chocolate, but they can call it "chocolate candy," or "chocolatey," or the even more obtuse and deliberately misleading: "made with chocolate."
Cybele May of Candy Blog says: "A lot of people don't notice it. The package looks exactly the same. I feel betrayed by Hershey's. They're giving me an inferior product and they're not even telling me. I call it mockolate, which is basically a fake chocolate product."
Consumer response to the changes is mixed in blind-tasting panels: some people prefer the new formulations over the old. When told about the changes, however, some consumers were alarmed, saying they felt "kind of cheated."
Perhaps more far-reaching in its implications is the fact that cocoa butter protects the antioxidant properties of the chocolate and does not raise cholesterol levels. From a calorie and fat content perspective, the mockolate may be similar to chocolate, but nutritionally, the reformulated products may fall short of predecessors. And consumers who read that chocolate is healthy, may not know the difference.
I have come to believe that manufacturers rely on the mental inertia of consumers. Once someone reads the ingredients and nutrition labels of a product (if they ever do) and decides the product is okay to throw in the shopping cart, they rarely go back and revisit the labels to determine if anything has changed. This is even the case when something is labeled "new" and "improved." New it may be, but does the "improvement" benefit the consumer or the manufacturer?
Do you prefer the new Hershey formulations to the old? Were you even aware of new formulations? Does a chocolate by any other name taste as sweet? Do you ever re-examine labels for products you've already decided are worth buying?
About the author: Clay Gordon has been a professional chocolate critic since 2001. His first book on chocolate, Discover Chocolate was selected as a finalist in the International Association of Culinary Professionals' 2008 Cookbook of the Year Awards. A serious chocolate educator, Clay has created and moderates an online community for chocophiles and aspiring chocophiles - The Chocolate Life.