Greetings and welcome to the strangest crossover I’ve ever been involved with.

I am #13, the host of the Ancient and Esoteric Order of the Jackalope, a podcast and/secret society devoted to the idea that which is least known is best to know. At the same time I’m also Dave from Chocolate Snobs, where my wife Dorothy and I rank all the chocolates from fanciest to schmanciest.

So… Welcome to the Ancient and Esoteric Order of the Chocolope, where I dive into topics too nerdy for a Chocolate Snobs episode and too chocolate-oriented for an Ancient and Esoteric Order of the Jackalope entry.

Today’s topic: “How Much Chocolate is in Your Chocolate?”

Apples and Oranges

So, first, let’s define what we mean when we say chocolate.

Europeans often make a big deal out of the fact that “American chocolate” (by which they man almost exclusively Hershey’s chocolate and/or candy bars) does not count as “chocolate” in the EU or UK. They are right, but they shouldn’t be too proud about it because the two standards are not as different as they think they are.

American regulations are concerned with the amount of “chocolate liquor” — i.e., a mixture of cacao nibs and cocoa butter that has been ground into a paste or fluid that’s about 50% fats.

The European regulations are concerned with the total amount of “cocoa solids” — not the dry cocoa solids, as you might imagine, but all cocoa material, including any fats that might be in chocolate liquor and any cocoa butter that is added to the chocolate liquor during the production process.

(American chocolatiers also add more cocoa butter to their product, it’s just not regulated in the same way.)

This makes it hard to come up with a good 1:1 comparison between the American and European chocolate standards, and it kind of makes you want an international standard.

Just to make it clear, European standards are what chocolatiers makers are referring to when they tout the amount of cacao in their bars. That’s why you can have a 100% chocolate bar that’s not just a gravely lump of cocoa nibs and cocoa powder. It’s because a significant part of that is cocoa butter.

Milk Chocolate

Next, let’s cover the chocolate with the least amount of actual cocoa in it: milk chocolate.

In America, milk chocolate must contain at least 10% chocolate liquor, 12% milk solids, and 3% milkfat. Most manufacturers are going to be adding at least 10% more cocoa butter but, again, that quantity is not regulated.

In Europe, milk chocolate must contain at least 25% cocoa solids and 14% milk solids. Just so we’re comparing things on an even footing, those 25% cocoa solids must contain at least 14% chocolate liquor. So, yes, European chocolate does have more cacao. But it’s not 150% more cacao as they like to claim.

Oh, and before the British get all snooty, your milk chocolate doesn’t meet European standards either. The regulations in Commonwealth countries require milk chocolate to have 20% cocoa solids and 20% milk solids. As such, it can only be sold in the EU as “family milk chocolate.”

Frankly, this whole argument is pointless anyway. You are literally comparing the worst chocolate in America to the worst chocolate in Europe, and it’s all pretty rotten. I’m all for a good Hershey’s vs. Cadbury’s vs. Milka argument as much as the next guy, but to chocolate snobs, they’re all crap.

In Canada, mik chocolate must contain at least 25% cocoa solids, 12% milk solids.

In Japan, we’re looking 21% cocoa solids, 14% milk solids.

(Also, a little aside: no government seems to care whether you use fresh milk or milk powder, but that’s a key difference here. Most Swiss-style milk chocolate uses milk powder, while British and American companies developed processes that used fresh milk instead.)

Dark Chocolate

Okay, how about dark chocolate?

In Europe and Canada and Japan, dark chocolate must have at least 35% total cocoa solids, with at least 18% of the total product being cocoa butter and 14% being dry chocolate solids.

In America, dark chocolate must be 35% chocolate liquor. That’s it. So our lowest-end dark chocolate is darker than European dark chocolate but not by much.

The Commonwealth countries have no specific regulations concerning dark chocolate.

White Chocolate

As for white chocolate… white chocolate is not chocolate.

Okay, sure, it is made from cocoa butter, but it has no dry cocoa solids. If “contains cocoa butter” is your only criteria, then I have several fancy hand lotions which count as chocolate. The same thing goes for blonde chocolate, which is just caramelized white chocolate, not that anyone is doing that anymore.

The jury’s out on ruby chocolate. Based on existing descriptions of the process it probably counts as chocolate but it’s hard to say while the process is exclusive to Callebault. I might revisit this when the process is no longer proprietary and more people start making it. Then again there’s not a ton of demand for ruby chocolate either, but that may be because it’s so exclusive no one cares.

I don’t care about other forms of chocolate — like bittersweet or semisweet — because they’re not meant for direct human consumption.

Cocoa Butter Equivalents

Now let’s talk about Cocoa Butter Equivalents — i.e., vegetable fats.

Why would you want to add vegetable fats to your chocolate? Larger quantities of fat make the chocolate more pourable when liquid, more ductile when solid, and reduces the need for tempering. It makes it easier to get a smooth consistent texture. When you increase the quantity of fat purely by adding cocoa butter, you get what’s called couverture. But cocoa butter is expensive, so you might want a cheaper option. And that’s when you get a compound chocolate.

In Europe and the Commonwealth countries, your chocolate can contain up to 5% of non-cocoa based vegetable fats, usual palm oil or shea oil. If you do so, you must include a disclaimer saying “Contains vegetable fats in addition to cocoa butter.” But you can still call your product chocolate.

In the United States and Canada, the presence of any non-cocoa vegetetable fats means you have to call your product “chocolate and vegetable fat.” That’s the one area where we beat Europe hands-down.

(On the other hand, the Japanese are apparently far more permissive when it comes to the amount of vegetable fats in chocolate. Pretty much anything goes. Which makes sense because Japanese chocolatiers seem to be obsessed with texture above everything else.)

Chocolatey

Now, let’s contemplate the unthinkable.

What would happen if you replaced all the cocoa butter in your chocolate with vegetable fats. Why, you ask, would someone want to do that? Greed. Cocoa butter is highly versatile and expensive. Sure, you could put it into a chocolate bar that retails for $5, but you can make a lot more money by putting it one of those aforementioned bottles of lotion.

However, once you’ve removed all the cocoa butter from your product, you can no longer call it chocolate. Instead, it has to go by some other name, like “chocolate candy” or “chocolate flavor” or “chocolatey.”

The good news for us, the, snobs, is that this generally doesn’t apply to us. What we’re buying is almost always actual chocolate. A Hershey’s milk chocolate or a Cadbury dairy milk might only be 20% chocolate, but it’s still pure chocolate.

The impostor not-really-chocolates tend to pop up where chocolate isn’t the star — chocolate coatings and candy bars. Especially candy bars. Almost every candy bar has a chocoately coating instead of a chocolate coating.

As a snob I should probably be above the fray, but I can’t stop feeling like this is an abomination. Bean counters are taking real chocolate away from you. I do not want to live in a world where Snickers bars are made out of chocolatoid flavoringos, but that seems to be where we’re headed. Back in the 1970s, angry British pub-goers formed the Campaign for Real Ale. Maybe we need a Campaign for Real Chocolate?

Pressure campaigns can work. Earlier this year Hershey’s reversed course and announced they would start making their candy bars with real chocolate again, after enormous social media pushback. (Though we’ll see whether they actually do it — Hershey switched because the price of cacao shot through the roof this year, and it doesn’t seem like it’ll be coming down while the president is obsessed with tariffs.)

And there you go. That’s how much chocolate is in your chocolate. At least, according to law. As always, until next time remember: that which is least known, is best to know.