.
TO: Division of
Dockets Management
Food and Drug Administration
5630 Fishers Lane, Room 1061 (HFA-305)
Rockville, MD, 20852
SUBJECT: Docket Number # 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
Dear
FDA:
We
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). We understand that as part of this petition, the CMA has petitioned
the U.S. Food and Drug Administration (FDA) to approve a change in the
Standard of Identity for chocolate products to allow for the use vegetable
fats in chocolate and milk substitutes and to be permitted to call the
product chocolate. We are opposed to these changes and say to GMA/FPI and
particularly to the CMA,
“Don’t Mess with Our Chocolate”
We
love it just the way it is; made with 100% cocoa butter and real milk,
rather than some concocted blend of fats and other substitutes. The
following lists the primary reasons why we oppose their petition and why
this is not in the best interest of the consumer:
-
Without proper labeling, consumers will find it difficult and confusing
to differentiate the current gold standard of real chocolate vs. this
new concoction, which has substitute ingredients. This will amount to
economic fraud to the consumer as the product will become cheaper with
inferior ingredients.
-
None of what is being proposed benefits the consumer, nor was any
consumer research submitted to support such changes.
-
Their proposed formula will contain large quantities of bad Trans fats,
which are not good for your health.
-
They are meddling with everything that we love about chocolate.
-
Cocoa butter is unique; vegetable fats can only masquerade as cocoa
butter.
-
The eating properties, flavor and mouth feel will all be different.
-
All manufacturers, even those who do not want to support this, will be
forced to convert to the new concoction due to the economic advantages
associated with the new formula and their wanting to remain effectively
competitive within the category. The net effect will be a total
downgrade in the eating enjoyment and quality for chocolate.
For
these reasons above, we strongly urge you to not allow the gold Standard of
Identity of chocolate to be changed. Thank you for your support in sending
the message to the CMA/GMA/FPA:
“Don’t Mess with Our Chocolate”