AMA: Ask Me Anything (About Cocoa or Chocolate) #7: Is White Chocolate Really Chocolate?

AMA: Ask Me Anything (About Cocoa or Chocolate) #7: Is White Chocolate Really Chocolate?

The Question

This is not normally put in the form of a question, just as an assertion. White chocolate, because it does not contain any cocoa liquor (i.e., it’s not brown) is not really chocolate.

But is it though? Really?


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. Most white chocolate may not be worth the calories, but that is not sufficient reason to deny its existence.

Few places serve to perpetuate the myth that white chocolate is not really chocolate more than the twin temples of the Internet: Twitter and Facebook. In this AMA I aim to set the record straight. Hopefully once and for all, but I am not sanguine about that possibility.

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 non-fat cocoa solids – what’s left over after the fat (cocoa butter) is removed from the paste (aka cocoa liquor) made of ground up cocoa nib. Even though white chocolate does contain cocoa butter, that’s not enough for some people to consider it chocolate.

Let me set the record straight for anyone and everyone: white chocolate is chocolate. Really, truly.


This is not an alternative fact and it’s not subject to interpretation or subject to someone’s personal feelings about taste, texture, or composition. 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 (sometimes also referred to as 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 legally chocolate. §21.163.124 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 §21.163.124 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 § Nomenclature: The name of the food is “white chocolate.” There are no ifs, ands, or buts. §21.163.124 is the definition for white chocolate and it is not open to second guessing. And there are similar entries in the Codex Alimentarius, which most countries refer to to harmonize food standards.

Unfortunately, there is no entry in Snopes on this topic, though I have brought it to their attention. (For those of you who may remain skeptical and want to do more research.)

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, for any reason. The only way around this is to change the law. Whether or not you believe white chocolate is not chocolate 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.

But let’s be real here, and recognize that a lot of the appeal of white chocolate comes down the texture (because there are no non-fat solids and a complete lack of bitterness.

White chocolate is, in a nutshell, mostly sweetened fat.

As a species, homo sapiens is genetically programmed to crave sugar and fat. When you factor in the experience of chocolate melting in the mouth, you have the potential for the perfect edible trifecta.

But is there such a thing as good white chocolate?

Yes. Oh my goodness yes, there is!

As with anything edible, the quality of a white chocolate depends on the quality of the ingredients. In white chocolate the ingredients that contribute most to flavor are the milk and the cocoa butter.

  • Try white chocolate made with full-cream dairy produced by cows eating tender grass growing in sun-drenched alpen glades in Switzerland in early Spring. One brand to try here is Felchlin.
  • Try white chocolate made with undeodorized cocoa butter, maybe Icoa from the Venezuelan company El Rey. The beans used for the cocoa butter are very heaviy roasted and this roast is apparent in the finished white chocolate.
  • Try white chocolate made with goat’s milk. Askinosie makes a very nice one with pistachios.
  • Try any white chocolate made by a small specialty/craft chocolate maker who presses their own cocoa butter.

Whatever you do, don’t judge all white chocolate based on your experiences with cheap drug store Easter bunnies.


What are your thoughts about white chocolate? Please share with the community in the comments below.

If you are a member of the media and want to engage with me on any or all of these topics or any other, please send an email to

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