Yes, Virginia, There is Such a Thing as White Chocolate

There is a persistent belief that white chocolate isn’t actually chocolate. It is. Really.

Few places serve to perpetuate this myth more than the twin temples of the Internet: Twitter and Facebook. In this post we aim to set the record straight once and for all ...

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 made of ground up cocoa nib. Even though white chocolate does contain cocoa butter, somehow it’s not chocolate.

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

This is not an alternative fact and it’s not subject to interpretation or subject to your personal feelings about taste or texture. 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 (also called 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. §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 §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 CFR Nomenclature: The name of the food is “white chocolate.” There are no ifs, ands, or buts. §163.124 is the definition for white chocolate and it is not open to second guessing.

Unfortunately, there is no entry in Snopes on this topic (though I have brought it to their attention), for those who are still skeptical. 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. The only way around this is to change the law.

Ironically, most people don’t know that there is no legal definition for dark chocolate. What is referred to as “dark” chocolate actually falls into the category of “sweet” chocolate (§163.123). And, just to make things even crazier, there is no formal legal distinction between semisweet and bittersweet chocolate. Unknown to most, §163.123 allows sweet chocolates to contain dairy ingredients, including:

  • Cream, milkfat, butter;
  • Milk, concentrated milk, evaporated milk, sweetened condensed milk, dried milk;
  • Skim milk, concentrated skim milk, evaporated skim milk, sweetened condensed skim milk, nonfat dry milk;
  • Concentrated buttermilk, dried buttermilk; and

Malted milk.

Take a look at the front label on a bar of Hershey’s Special Dark® (45% cocoa content) Chocolate. You will notice that “Special Dark” is a trademarked term. Elsewhere on the front label you will find the phrase “mildly sweet chocolate.” This is to let regulators and inspectors know which section of CFR 21.163 the chocolate falls into.

If you take a look at the ingredients list you will find milk fat and lactose (milk). Lactose is a milk sugar. I am not making these things up. Go look them up for yourself.

All of the above information about white chocolate is objectively factual.

It 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. I won’t disagree with the observation that a lot of white chocolate is not worth the calories. What determines the quality of a white chocolate is the quality of the ingredients.

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. Much of the appeal of white chocolate is the texture. Because there are no non-fat solids (the brown part), white chocolate is basically just smooth sweet fat.

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

I can tell you from personal experience that white chocolates made with undeodorized cocoa butter (cocoa butter that has not had the flavor and aroma chemicals removed) will change your mind about white chocolate. They did mine. I can tell youfrom personal experience that white chocolates made with exceptional dairy will also change your mind - assuming you are open to the possibility.

Try white chocolate made with goat milk. Or white chocolate made with full-cream dairy produced by cows eating tender grass growing in sun-drenched alpen glades in early Spring and undeodorized cocoa butter. But please don’t judge all white chocolate based on your {{ shudder }} experience with drug store Easter bunnies.

In closing:

  • Yes, there is such a thing as white chocolate.
  • Be open-minded: don’t assume every white chocolates sucks just because the ones you’ve eaten suck.
  • Don’t believe everything you read on the Internet. (But you can believe this.)

Still not convinced? What is your reasoning?

Updated to fix formatting, typos, and grammar on 11/20/17.


I agree with @DiscoverChoc and @liz -- white chocolate is fine, it's just a different animal than the dark stuff. For my money, white chocolate is where quality is even more imperative or it can come dangerously close to tasting like sweet wax. When it's good though, it's really good. Since it is much sweeter, I tend to think of it more as "candy", but a little is fine. As for parallels with "Sideways" -- I remember that when that movie came out, NO ONE wanted to be caught dead ordering Merlot. The Merlot winemakers took a huge hit from that flick. Such is the intimidation of cultural norms. Fortunately culture evolves. Even though I have trended towards darker and more artisan chocolate the past few years, I wouldn't criticize someone's liking of something more mass-produced. I'm not "to the manor borne" and snobbishness is annoying.


@liz - I think for most people, admitting that they like chocolate is a lot like ordering a White Zinfandel. You can't really like wine if that's what you drink. I think the larger issue is about snobbishness, which, IMO, has no place in chocolate. We never want to get to that place where in the movie Sideways, Paul Giamatti's character tells Thomas Hayden-Church's character in the alley, ”If anyone orders the merlot I'm leaving.” What you like is what you like - don’t let anyone try to take that away from you. Ever.


@Marika_Amsterdam - Most people I know who just assume that white chocolate is not really chocolate come to that conclusion because ... it’s not brown. In order to really be chocolate it has to include non-fat cocoa solids (cocoa powder).


@Marika_Amsterdam - From the Wikipedia summary:

“Yes, Virginia, there is a Santa Claus” is a phrase from an editorial called ‘Is There a Santa Claus?’ which appeared in the September 21, 1897, edition of The (New York) Sun and has since become part of popular Christmas folklore in the United States.