In order to qualify as chocolate, a product must contain cocoa solids. And white chocolate does no such thing. Instead, it’s usually made from a combination of cocoa butter, lecithin (a fatty emulsifier), milk products, sugar, and vanilla.
“But wait!,” the white chocolate lovers might say. “Doesn’t the cocoa butter count as chocolate?”
The answer is once again, “nope”. Cocoa butter is derived from cocoa beans, but it doesn’t contain the cocoa solids that define chocolate. Here’s how it works: When cocoa beans are harvested, they’re extracted from their pods and then put through a fairly lengthy process that involves being fermented, dried, roasted, opened, and shelled. Inside of that shell is the chocolate nib, which then gets ground into a paste to form chocolate liquor. That liquor then gets divided into cocoa solids (which are responsible for providing the chocolatey flavor and brown color found in dark and milk chocolates) and cocoa butter (which is essentially just fat without much flavor).
Only cocoa butter (not cocoa solids) is used in the process of making white chocolate. Because the cocoa butter doesn’t really taste all that great on its own, it gets added to the other ingredients listed above in order to confer the smoothness and sweetness that you probably associate with white chocolate. In the U.S., the FDA mandates that white chocolate contains at least 20 percent cocoa butter, 14 percent milk solids, and 3.5 percent milk fat. Sugars and other sweeteners must be limited to no more than 55 percent of the product.
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