What is Our Change.org Petition About? | #PSC 233
OVERVIEW: Episode 233 of #PodSaveChocolate is an explainer about our recently created petition on Change.org. What is it asking, what is not asking, and what YOU can do to make sure the FDA hears our concerns.
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Episode 233 Overview
I started a petition on Change.org that urges the FDA to prohibit products made from āengineered cocoa substitutesā (my preferred term over lab-grown cocoa) from being labeled as chocolate.
In other words, āKeep Chocolate Tied to the Cacao Tree.ā A standard of identity that no longer identifies anything is not a standard.
If you agree, sign the petition (link below) and encourage others to sign it, too!
Sign the Petition Today & Show Your Support
In support of a citizen petition to the U.S. Food and Drug Administration (āFDAā), urging them to not amend 21 CFR Part 163 to permit products made with engineered cocoa substitutes (materials produced by microbial fermentation, plant cell culture, enzymatic synthesis, or any comparable technology now known or later developed), to be labeled āchocolate.ā
Instead, establish āartificial chocolateā or āengineered chocolateā as the required common or usual name for those products, and permit ānatural chocolateā as an optional designation for products made from the seeds of the Theobroma cacao tree.
Part 10Filing a Citizen Petition with the FDA is the next step, assuming sufficient signatures are collected at change.org.
What the citizen petition will not ask
We are not asking the FDA to prohibit engineered cocoa substitutes, to restrict the underlying technology, to require warning statements, or to make any finding about safety or nutrition. (Safety review belongs in the GRAS and food additive pathways, where it is already proceeding.)
We ask that these products be named accurately.
Distinct nomenclature has not suppressed plant-based dairy or cultivated protein; both categories have grown under qualified names. Clear naming serves these manufacturers as well, by letting them market the specific attributes of their process rather than borrowing an identity that describes something else.
What the citizen petition will ask
- Decline to amend Part 163 in any manner to admit inputs not directly derived from the tree-grown seeds of Theobroma cacao into the standardized foods defined therein..
- Establish āartificial chocolateā or āengineered chocolateā as the required common or usual name for any product in which cocoa solids or cocoa butter are wholly or partially replaced by an engineered cocoa substitute, with the substitute and its production method identified in the ingredient statement.
- Permit ānatural chocolateā as an optional designation for products conforming to Part 163 and made from tree-grown cacao.
- Apply the same rule to derived terms, including ācacao,ā ācocoa,ā ācocoa butter,ā ācocoa powder,ā and āchocolate liquor.ā
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Future Episodes
First impressions on the new āCertified Ceremonial Cacaoā certification trademark.
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