What is White Chocolate? Is White Chocolate Really Chocolate? Does It Matter?

by | Aug 6, 2020 | Chocolate Information

White chocolate gets the short end of the stick, ranking last on the chocolate triumvirate of dark, milk and white.  For some chocolate purists, milk chocolate may not even be chocolate.  White chocolate does not even get a mention.  On the other hand, appreciation of white chocolate – high-quality white chocolate – is growing among chocolate connoisseurs.  The key element, as it is in all chocolate, is quality.  What some chocolatiers are creating with white chocolate is truly amazing.  So let’s plunge into the debate.

  1. White Chocolate Defined.

Regulations govern what may be marketed as “white chocolate.”  Since 2000 the European Union has stated that white chocolate must be (by weight) at least 20 percent cocoa butter, 14 percent milk solids and 3.5% milk fat.  [Directive 2000/36/EC of the European Parliament and of the Council of 23 June 2000].  Since 2004 these same standards apply in the United States, with the additional provision that the product can include no more than 55% sugar or other sweeteners.  [21 Code of Federal Regulations § 163.124].  Now that we have the legal side covered, what do the experts say?

  1. No Way Is White Chocolate Chocolate.

The white chocolate naysayers claim white chocolate is not really chocolate because it does not have the rich, nuanced flavor that dark and milk chocolate provide.  Chloé Dontre-Roussel, in her book, The Chocolate Connoisseur (Penguin Books 2006), expresses her disdain for “white chocolate”, stating, 

White Chocolate

I don’t have much regard for this.  White chocolate is made with cocoa butter, but contains no actual cocoa mass.  In my opinion, it’s about as tasty as eating a piece of paper coated with sugar and milk powder!  

Id. at p. 173

The white chocolate naysayers point to the chocolate-making process to make their point.  Nibs are extracted from the cacao bean.  These nibs are then ground into a paste which is called chocolate liquor.  However, no alcohol is involved.  The chocolate liquor can be separated into two parts:  cocoa solids, which is where the traditional dark and milk chocolate flavors originate and cocoa fat, also known as cocoa butter.

White chocolate does not contain cocoa solids.  Although one of white chocolate’s key ingredients is cocoa butter, it lacks flavor – and chocolate purists are all about that chocolate flavor.  Plus, white chocolate only has to contain 20% cocoa butter.  The rest of that white chocolate bar can be made up of sweetener, dairy products emulsifying agents, spices, flavorings and whey.  So, if you do not have chocolate liquor in your chocolate, it is not chocolate.

  1. Yes, White Chocolate is Truly Chocolate.

 White chocolate advocates claim that chocolate purists are wrong to turn such a blind eye to white chocolate.  For many innovative chocolatiers, it is like a blank canvas that give them free reign to experiment with flavors, textures and colors.  When high-quality cocoa butter is used, that cocoa butter renders subtle floral and vanilla flavors, while the different dairy ingredients add structure as well as a subtle melody of cream, butter and yoghurt hints.

Cookbook author and white chocolate fan, David Lebovitz, disputes the idea that white chocolate is not chocolate.

“Bickering over the nomenclature becomes tiring.  We still call hamburgers by that name, even though they are not made of ham, and milkshakes actually are not shaken these days, but blended.  So I think it is okay to group white chocolate in with the rest of the variety of things made from cacao beans, since they all have the same base.” 

[Sethi, The Washington Post, “For Those Who Think White Chocolate Isn’t Real Chocolate, We Have Got Bars for You.” (November 27, 2017)].

White chocolate makers are pushing the boundaries with flavors.  Chocolatiers are utilizing non-deodorized cocoa butter that retains cocoa butters.  The non-deodorized cocoa butter was popularized by the Venezuelan company El Rey.  In buying white chocolate, check the color.  High-quality white chocolate tends to be slightly yellow because cocoa butter is naturally yellow.  If the chocolate is white, the chocolate has probably been bleached and probably deodorized.  The flavor may be lacking.

  1. So Does It Matter?

 As the Chocolate Savant, I am not a purist.  I am a lover of all things chocolate.  For me, it comes down to taste.  Does the chocolate create a memory – is it worth writing about.  And the ultimate – is it a chocolate explosion?  In my opinion, the most reasoned analysis of whether white chocolate is really chocolate was expressed by Clay Gordon in his book, Discover Chocolate.  The Ultimate Guide to Buying, Tasting and Enjoying Fine Chocolates.  (Gotham Books 2007):

Is white chocolate really and truly chocolate?  Even the experts are divided on this one.  Legally, according to the FDA, there is such a thing as white chocolate.  Purists will say that because there are no cocoa solids in white chocolate, it doesn’t deserve to be called chocolate.  In the end, no one can force you to eat anything you don’t want to eat, so who cares what it’s called and whether it’s really chocolate or not?  

Id. at 151.

So give white chocolate a try.  Maybe some fine red wine and some artisan white chocolate would taste great tonight!


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