Yes, the sweetest and most indulgent type of chocolate is often the object of heated debates. Although it sounds like a trivial dispute among chocolate snobs, the discussion around white chocolate is quite an intriguing one that touches on legislation, flavor, health, and transparency. You will be surprised by how many times the question “Is white chocolate real chocolate?” appears on Google research. The results are always 50/50 depending on the source, the desire to be sensational, and the seriousness of the writer.

To me, answering that question is irrelevant. Those who like white chocolate will keep enjoying it regardless of what others say, and the white chocolate haters won’t be convinced any time soon. I’m actually more interested in taking advantage of this debate to spark a light on white chocolate.

What is White Chocolate Made Of?

Inside a cacao bean, we find the cocoa butter and the non-fat cocoa solids (aka the brown part). The cocoa butter is all fat, while the brown part is what gives chocolate its typical brown color, complex flavors, and where most of the nutrients are (carbohydrates, proteins, minerals). The ratio is usually 50/50, but it varies depending on many factors in the country of origin (genetics, terroir, harvest year, etc.)

Up until 1828, it was not possible to separate the cocoa butter from the non-fat solids. Only when Coenraad Van Houten, Dutch chemist, and chocolate maker, invented a machine that could squeeze the cocoa butter out of a pre-refined cocoa paste, chocolatiers had this new creamy ingredient to work with. The invention of white chocolate is attributed to Nestlé around the 1930s.

Regardless of a chocolatier’s preference and creativity, you can be sure that white chocolate will:

  • never contain non-fat cocoa solids. The only part of the cacao bean used in white chocolate is cocoa butter, therefore the fatty part (the “brown part” isn’t used at all).
  • always be made with sugar, cocoa butter, and milk/mylks. Ingredients may vary (from different sweeteners to plant-based alternatives), but this trio is the official base for white chocolate.
  • always contain more fats and sugars than all the other kinds of chocolate.
  • still be an expensive chocolate to make. Just because it doesn’t have the precious non-fat solids, it doesn’t mean that white chocolate is made with the “waste” of chocolate production. Actually, cocoa butter is a very expensive ingredient.

How the Law Defines (and Doesn't Define) White Chocolate

In the US, Europe, and the UK, white chocolate is legally defined as follows:

"To be marketed as white chocolate, a product must contain at least 20 percent cocoa butter, at least 14 percent total milk solids, and at least 3.5 percent milkfat."

While the FDA imposes a limit of 55% added sugars (they call them nutritive carbohydrate sweeteners), the European legislation doesn't mention any limit. Also, chocolate that isn't made with dairy ingredients but with plant-based alternatives such as coconut, oat, rice, or almond flours/powders can't be legally called white chocolate. Finally, the law allows for extra ingredients: natural and artificial flavorings, spices, whey products, emulsifying agents, and more.

If this is the bare minimum that chocolate professionals must hit to call their products white chocolate, you can see for yourself how there is a lot of space to leverage and manipulate the ingredients list. For example:

  • literally half or more of the chocolate bar can be just sugar;
  • the definition of nutritive carbohydrate sweeteners includes Sucrose, Dextrose, Corn sugar, High Fructose Corn Syrup, and all types of Sugar Alcohols;
  • all sorts of flavorings are accepted (to mimic the taste of natural ingredients or to cover up the poor quality of the chosen cocoa butter and milk)

These rules apply only to the brands that actually care to put a WHITE CHOCOLATE claim on their packaging. Those who don’t care for this label can truly go wild with fillers, vegetable fats, powders, and other debatable additives. To avoid being sued, these brands invent words, claims, and images that suggest white chocolate without actually saying it out loud. But do you want to know the funniest part?

White chocolate is legally MORE chocolate than 100% cacao bars. For the law, if a product doesn’t contain sugar, it can’t legally be called chocolate. So while true chocolate lovers, connoisseurs, and professionals care for the delicate flavors that the non-fat cocoa solids can deliver even without the sugar, legislators seem to reward the presence of sugar more than anything else.

This loose and permissive definition is one of the reasons for the never-ending white chocolate controversy, but there is more.

Where Does the White Chocolate Controversy Stem From, Really?

Sure, the fact that the law allows for so many extra ingredients to be in white chocolate is upsetting. But some chocolate lovers would look down on white chocolate even if every single bar on the market only contained cocoa butter, milk, and sugar. Why many don’t consider white chocolate to be “real chocolate” can be summarized in 3 main reasons.

  1. White Chocolate Doesn’t Contain Non-Fat Cocoa Solids: Without the “brown part”, white chocolate lacks the typical deep brown color associated with chocolate, together with its unmistakable flavor and most of the health benefits associated with cacao. Many consider the non-fat cocoa solids of the cocoa bean to be superior to its bland and fatty counterpart. Although cocoa butter makes up half of the cacao beans just as much as non-fat dry solids, they believe that real chocolate should be made with both. After all, it took the invention of a complex and expensive machine to separate the two.

  2. White Chocolate Isn’t as Healthy as Dark Chocolate: White chocolate objectively contains more fats and sugars, and less proteins and minerals than the other kinds of chocolate (especially when compared to dark chocolate). And this is only in the best case scenario where brands choose to be minimal with their ingredients. When it comes to mass-produced white chocolate, the ingredients list starts to become a carnival of debatable additives and fillers that do more harm than good to the human body.

  3. White Chocolate Lacks Depth of Flavor: No matter how many inclusions, different textures, and sensorial experiences chocolate makers come up with, white chocolate will never have the width and depth of flavors that fine dark chocolate naturally delivers. It’s only fair to mention that the high-quality and undeodorized cacao butter that some chocolate makers use can carry delightful flavor subtleties. But again, nothing compared to the broad variety that can be tasted when non-fat cocoa solids are present.

So is white chocolate real chocolate?

For the law, YES. For connoisseurs and sommeliers, NOT SO MUCH. But what about regular consumers which are actually the main target? The debate doesn’t seem to affect them. On the contrary, they are absolutely LOVING IT!

A Renewed Strong Demand for White Chocolate

In 2023, the chocolate market seems to be further than ever from the 2016 hype around sugar-free, health-conscious, superfood-enriched, and functional dark chocolate. Sure, some protein-rich chocolate bars still find their audiences, but those old days of sugar restriction in the chocolate industry are far gone. Might be the longing for more comforting chocolate to cope with these harsh times, or the fact that white chocolate truly presents itself as a white canvas for professionals to express all their creativity, but white chocolate is surely back to be a favorite.

Once relegated only to special editions during the holiday seasons or for special celebrations (Mother’s Day, Valentine’s Day, etc.), white chocolate is now a staple in every chocolate brand’s assortment (even the diehard dark chocolate makers had to succumb to the incessant request for sweeter creations from consumers). It followed that, what used to be plain white chocolate that tasted like a sugary stick of butter, has now developed into infinite flavors, textures, and nuances: savory, sweet, crunchy, silky, colorful, dairy-free, and beyond. There seems to be no limit to the creativity that chocolate makers can express with white chocolate. And those are ironically the bars that sell out all year round.

However, the new demand for white chocolate now includes a closer attention to the ingredients list, a preliminary research on the chocolate brand, and a demand for higher quality ingredients.

Final Thoughts

Cocoa butter is still an integral part of the cacao bean, and white chocolate is still considered a legit type of chocolate. The controversy around white chocolate will continue infinitively, with everybody entitled to their own opinions. But the market is the market, and it’s now asking for that extra hug that only white chocolate can deliver.


  1. Is white chocolate real chocolate?

    • Yes, according to the law, white chocolate is considered real chocolate due to its cocoa butter content. However, some connoisseurs and professionals may not consider it as such due to its lack of non-fat cocoa solids.
  2. What are the basic ingredients of white chocolate?

    • White chocolate is made with sugar, cocoa butter, and milk/mylks. While the exact sweeteners and milk alternatives may vary, these three ingredients form the base of white chocolate.
  3. Why is white chocolate controversial?

    • The controversy surrounding white chocolate arises from its composition, health concerns, and flavor limitations compared to dark chocolate.
  4. Is white chocolate healthier than dark chocolate?

    • No, white chocolate is not as healthy as dark chocolate. It contains more fats and sugars and fewer proteins and minerals, making it less nutritious than its darker counterpart.
  5. Why is there an increasing demand for white chocolate?

    • The demand for white chocolate has increased due to its versatility as a canvas for creativity in the chocolate industry, resulting in a wide range of flavors and textures.
July 20, 2023 — Ryan Dunn

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