So, as you may remember, the FDA is considering a request from Grocery Manufacturers Association/Food Products Association (GMA/FPA) to approve a change in Chocolate. To wit, they would allow companies to label items “chocolate” which have no cocoa butter in them, but are instead hydrogenated trans fats. Up with this I will not put!
Today is the last day to get your comments into the FDA opposing this. Considering the fact that chocolate is the sole reason I haven’t gone on a rampage during that “special” week once a month…and I know I’m not the only one…consider taking a few minutes to voice your opinion here. It’s a long ass process, as the FDA isn’t really interested in what consumers want, but even with that, it’ll only take about five minutes to go through all the steps.
Don’t know what to say? Here’s what I said.
Docket # 2007P-0085
Adopt Regulations of General Applicability to all Food Standards that would Permit Deviations from the Requirements of the Individual Food Standards of Identity
Ladies and Gentlemen of the FDA,
I solicit your support against the proposed and pending changes to chocolate (Docket # 2007P-0085), submitted by the Grocery Manufacturers Association/Food Products Association (GMA/FPA) on behalf of a number of organizations including the Chocolate Manufacturers Association (CMA).
This petition asks the FDA to approve a change in the Standard of Identity for chocolate products to allow for the use vegetable fats and milk substitutes and still be permitted to call the product chocolate. (Current FDA standards do not allow this; see CFR Title 21, section 163.)
There is no reason to change a definition that has worked for hundreds of years, other than to gain a short term fiduciary benefit to the manufacturers. Listed below are a number of reasons why this petition should not be allowed, and why it should be considered an anti-consumer request:
1.) Consumers have an existing understanding of what chocolate is. This proposed labeling of trans fats and milk substitutes would constitute economic fraud on a vast number of unsuspecting consumers.
2). None of what is being proposed benefits the consumer, nor was any consumer research submitted to support such changes.
3). The proposed formula contains vast amounts of trans fats, just as the FDA is recognizing that those ingredients should be eliminated from consumer diets.
4). European chocolate makers will not be impacted by this labeling law, and thus dollars that could have been spent on American goods will be instead spent on European products, because knowledgable consumers will still buy “real” chocolate instead of flavored lard substitute.
The current labeling laws are arcane and convoluted, but they are understood. There is no reason to have to reeducate an entire nation about what chocolate *is*, just to help the bottom line of manufacturers. If it costs more to product the “real” product, as it very well may, then that cost should be passed along to the consumers who want the “real” product. If they want to create lower cost substitutes, then those substitutes should be clearly labeled as such.