labeling chocolates

[Chocolot]

I am in the process of setting up my ingredients list for my boxes. These will be for retail packaging. The state lady in charge of labels is giving me fits over the colored cocoa butter. She wants every FD&C color listed that is in the box, regardless of the quantity. This means I will have a long list for perhaps 1 or 2 chocolates in the box. She even said that if it is a natural color it still has to be listed as artificial because it is not natural in chocolate. What have the rest of you done? Is she just being extra picky, or is this just the way it is? In checking with the supplier, he says to just list it as color, but she isn't buying it. Any suggestions? I know I could just eliminate those pieces, but that is what makes the box unique.

[emmalish]

Would you be allowed to break it down separately and say something like "Some pieces may contain..."?

[Sebastian]

that's bunk. according to the Code of Federal Regulations (CFR), the legislation that documents how we handle, amongst other things, food labeling, your state lady is, how do i say it, full of crap. If the color being used in your cocoa butter meets the federal definitions of 'natural color' (your supplier can tell you if it does or doesn't), then you label it according to those legal definitions (ie natural color or artificial color). If it's white, it'll be artificial color, as TiO2 is the only FDA approved white colorant, and it's going to be considered artificial. All of the others will depend on what they're made from.

She is correct, however, if you've got an ingredient present, no matter how small, you need to label it. Unless it's considered a processing aid, but that's a whole 'nother ball of wax, very complicated, and won't work for colored cocoa butter at the end of the day, so i'll stay away from it...

[Chocolot]

that's bunk.  according to the Code of Federal Regulations (CFR), the legislation that documents how we handle, amongst other things, food labeling,  your state lady is, how do i say it, full of crap.    If the color being used in your cocoa butter meets the federal definitions of 'natural color' (your supplier can tell you if it does or doesn't), then you label it according to those legal definitions (ie natural color or artificial color).  If it's white, it'll be artificial color, as TiO2 is the only FDA approved white colorant, and it's going to be considered artificial.  All of the others will depend on what they're made from.

She is correct, however, if you've got an ingredient present, no matter how small, you  need to label it.  Unless it's considered a processing aid, but that's a whole 'nother ball of wax, very complicated, and won't work for colored cocoa butter at the end of the day, so i'll stay away from it...

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Thanks for your feedback. I bought a bunch of junk candy to see how the "big boys" label colors. Very interesting!! Many of them just list red 40, etc with no mention of color, artificial or otherwise. Not a lot of consistency. I'll work through it and be better educated in the end