Artwork check on an "Ecuador 72% Single Origin" bar
A small UK maker submits artwork for a 100 g bar. The front reads "Ecuador 72% Dark Chocolate", "Single Origin", "Bean to Bar" and "No Added Sugar". The recipe per 100 kg finished chocolate is: 45 kg cocoa mass from Ecuador, 15 kg cocoa mass from Ghana, 12 kg added cocoa butter from Malaysia, 27.4 kg cane sugar, 0.5 kg soya lecithin and 0.1 kg vanilla. The ingredient list currently reads: "Cocoa mass, cane sugar, cocoa butter, vanilla, emulsifier (E322)". The bar is made on the same line as milk chocolate, and the back panel states "may contain traces of nuts" but nothing else. The retailer wants "72% cocoa" on the front and asks how the figure was derived; the buyer separately asks whether the added cocoa butter is deodorised and whether it counts towards the 72%.
1. List the labelling non-compliances on this artwork and the correction for each.
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Work through the pack against EU/UK food information rules (Regulation 1169/2011 as retained in UK law; cocoa products Directive 2000/36/EC):
- "Ecuador" as the origin of a blend. Only 45 of the 72 kg of cocoa material is Ecuadorian (62.5%); 15 kg is Ghanaian and the added butter is Malaysian. Naming a single country is misleading unless it is the origin of the characterising ingredient. Fix: "Ecuador & Ghana" or drop the country from the name and describe the blend in copy.
- "Single Origin". Factually false on this recipe. Remove it.
- "No Added Sugar". The bar contains 27.4% cane sugar. This is not a borderline claim - it is wrong. Remove it.
- Allergen declaration. Soya lecithin must appear as "soya lecithin" or "emulsifier: soya lecithin", emphasised (bold/underline/caps) in the ingredient list; "E322" alone does not identify the allergen.
- "May contain traces of nuts". There is no nut use described; an unsubstantiated precautionary allergen label is itself misleading. Remove it, or justify it with a documented allergen risk assessment.
- Milk cross-contact. Made on a shared milk line with no warning. Either add a justified "may contain milk" statement or demonstrate control (cleaning validation, dedicated equipment).
- Ingredient order. Descending by weight is correct as written (45 > 27.4 > 15 > 12 > 0.5 > 0.1). Vanilla is correctly placed last.
2. Is "72% cocoa" defensible, and how should the 72% and the added cocoa butter be explained to the retailer and buyer?
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Arithmetically, yes: 45 + 15 + 12 = 72 kg of cocoa-derived material per 100 kg. The number is correct as a total cocoa-solids figure.
But the composition behind it matters, and this is what the buyer is really asking. Split the 72 into its parts:
- Fat-free cocoa solids: 60 kg (all from the two masses; the added butter contributes no non-fat solids).
- Cocoa butter: 12 kg added on top of the butter naturally present in the masses - roughly 12% extra fat relative to the recipe.
So the bar is 72% cocoa material but has a materially higher fat-to-non-fat ratio than a bar made at 72% from mass alone. That is legal - added cocoa butter counts towards the declared cocoa solids - but it changes the melt, the intensity and the cost, and a buyer comparing against a "72% from mass only" competitor is entitled to know. The honest front-panel wording is "72% cocoa solids" with the derivation available on request, and copy that does not imply the 72% is all Ecuadorian mass.
On deodorisation: the Malaysian butter is almost certainly deodorised refined cocoa butter, which is standard for added butter and contributes fat and texture but no origin aroma. Say so plainly. If the buyer wants the cocoa butter to reinforce the Ecuadorian profile, the alternative is to raise Ecuadorian mass and lower added butter, which changes the recipe and the cost - quote both.
Compliance floor: the product still meets the EU minimum for chocolate (35% total dry cocoa solids, 18% cocoa butter, 14% fat-free cocoa solids) comfortably at 72/60, so no naming problem arises.
3. The retailer also wants a quantitative ingredient declaration (QUID) for the Ecuadorian cocoa. Advise on when QUID is required here and how it should read.
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QUID is triggered by the name, not by the marketing copy. Where an ingredient appears in the name of the food, its quantity must be declared as a percentage of the finished product. Once the front panel says "Ecuador", Ecuadorian cocoa becomes a characterising ingredient and must be quantified.
How it should read: "Cocoa mass (Ecuador) 45%" in the ingredient list, with the percentage calculated on the finished bar. Note that the added cocoa butter is Malaysian and therefore cannot be folded into the Ecuadorian figure - that is exactly the error the current draft invites.
Alternative, lower-risk route: remove the country from the product name, place the origin story in the descriptive copy with the blend stated honestly, and no QUID is triggered for origin. Many small makers take this path because blend proportions change with harvest, and a QUID locks the percentage into the label.
If the recipe will vary: do not put a fixed QUID on a blend that moves seasonally. Either fix the recipe contractually with your mass supplier or use the non-QUID naming route.
Practical checklist before print: re-verify the percentage against the actual production batch, not the development recipe; check that the emphasis formatting for soya survives the print proof; and have the buyer confirm in writing which front-panel claims they have approved, so that the responsibility for the origin claim is documented rather than assumed.