Bean to bar chocolate makers
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Tasting Notes
Steve:Have you run your interpretation past a lawyer who has experience arguing these kinds of cases with the FDA?All chocolate is, by definition, made from chocolate liquor. Chocolate liquor, by definition, is made from nibs. There is no provision for making chocolate from whole beans. Here are the references:Sec. 163.111 Chocolate liquor.(a)Description. (1) Chocolate liquor is the solid or semiplastic food prepared by finely grinding cacao nibs.Sec. 163.110 Cacao nibs.(a)Description. (1) Cacao nibs is the food prepared by removing the shell from cured, cleaned, dried, and cracked cacao beans.Sec. 163.123 Sweet chocolate.(a)Description. (1) Sweet chocolate is the solid or semiplastic food prepared by intimately mixing and grinding chocolate liquor ...^ included is the definition of sweet chocolate is bittersweet chocolateEven though you're grinding whole beans you are subject to the rules related to shell content
if you want to call your product chocolate. Right now, because you're not making your product from nibs, legally you can't call it chocolate. That's the way the Standards of Identity work. They determine what ingredients can be included in a food (and in many cases HOW it is made) if you want to use a certain word or term to describe it. Because your products use a process that is not in the Standard of Identity, my interpretation is that your product does not adhere to the Standard and therefore can't be called chocolate.But - I am not a lawyer and YMMV.:: Clay