Key takeaways from the cocoa label crisis
- Nestlé and Pladis removed the term chocolate from some UK products due to cocoa butter falling below the UK’s 20% legal minimum
- Poor growing conditions and crop disease have led to declining harvests and rising cocoa prices
- Firms like Cargill and Barry Callebaut are exploring alternatives to broaden options, but not to eliminate cocoa
- Replacing cocoa can trigger compliance issues with EU chocolate directives and organic product regulations
- Experts advise transparency and strict adherence to food information regulations to avoid misleading consumers
- Don’t expect labelling laws to relax. Regulators have shown limited flexibility, even during crises like the Ukraine war, according to legal experts
Nestlé and Pladis were forced to drop the word ‘chocolate’ from their white chocolate KitKats and Digestives, after cocoa butter levels dipped below the UK’s legal minimum of 20%, as revealed by The Grocer last month.
The news rattled KitKat and Digestives fans, though it came as little surprise to industry insiders who’ve watched cocoa prices climb steadily amid fluctuating harvest volumes.
The cocoa crisis – driven in part by poor growing conditions and crop disease – has prompted several savvy ingredients firms to explore alternatives. These aren’t just about replacing cocoa, but also meeting rising demand for vegan, clean-label and sustainable options.
Majors giving attention to alternatives in recent months include Cargill, which last year pumped €35m into a new chocolate-reducing facility. This focus is about tapping into nourishing the world in a “sustainable and responsible way”, Cargill EMEA group president for food solutions said last year.
That doesn’t mean the industry is turning its back on cocoa. “We believe that alternatives to chocolate aren’t about replacing cocoa – it’s about offering a new, more sustainable choice for people who are looking for something different, whether for curiosity, cost or environmental reasons,” says Cargill’s chocolate confectionery and ice cream category senior director Anne Mertens-Hoyng.
Providing choice will help to build a more resilient and inclusive food system, she believes.
The exploration of cocoa alternatives
Barry Callebaut echoes the sentiment. “We see the exploration of alternatives, such as cocoa cell culture technology, not as a replacement for traditional cocoa, but as a way to broaden the spectrum of cocoa-based ingredients available to our customers,” a spokesperson said.
“We believe many of our customers are increasingly open to innovative and sustainable solutions, especially those that align with evolving consumer expectations.”
Both companies are focused on expanding sustainable cocoa sources while continuing to support traditional cocoa farmers and communities.
But alternatives come with legal strings attached. “Due to the cost increases of some basic commodities such as cocoa, it is of course very appealing to turn to less expensive and less volatile alt ingredients,” explains Katia Merten-Lentz, partner at Food Law Science & Partners.
Recipe changes are rarely simple – especially at scale – where taste, texture and appearance all matter. But regulation is the real sticking point.
“Replacements could have legal consequences as well,” Merten-Lentz warns. “For instance, for organic products which require only organic ingredients in their composition. Or for ‘chocolate’ based foods which have to comply with the chocolate directive which allows only some alternatives to cocoa butter.”
How to use cocoa alternatives
So, are cocoa alternatives a legal no-go? Not quite. “Respect the mandatory particulars of the Food Information to Consumers Regulation (FIC),” she advises, including updating ingredient lists.
More critically, “if the replaced ingredient was highlighted somewhere on the packaging – whether in the name, description, or imagery – that change must be clearly indicated to avoid misleading consumers,“ she adds.
Cargill agrees. “Naming and labelling are critical when working with alternative ingredients, especially in sensitive categories like chocolate,” says Mertens-Hoyng.
The company works closely with customers to navigate regulatory frameworks across markets. “We understand that terms like ‘chocolate’ are strictly defined in many regions, including the EU, and can’t be used unless specific cocoa content criteria are met,” she adds.
With alternative ingredients on the rise – driven by consumer demand and supply chain pressures – could labelling rules be due for an overhaul?
Not likely, says Merten-Lentz. “We saw a critical situation during the Ukraine war, when last-minute commodity replacements were needed,” she recalls. “The only flexibility granted by national authorities was allowing ingredient lists to be updated with stickers instead of reprinting packaging.”
