I’ve written before about positive research on chocolate, here, here and here. I’ve written — the facts — about lead and cadmium in chocolate here.

Dark chocolate and cocoa powder are loaded with a subclass of antioxidants, called “flavanols”, thought to be behind many of the benefits attributed to these two foods.  Among the benefits attributed to dark chocolate and cocoa powder have been lower blood pressure, reduced risk for heart disease, and improved gut environment.  It’s all emerging research, but it looks promising.

Does The Research Justify a Health Claim? 

Sort of. There’s a process to this, and it takes years. Health claims are handled by the Food and Drug Administration (FDA) and they want to see a mountain of high-quality evidence before they allow their blessing of a health claim. 

Chocolate manufacturer Barry Callebaut, of Switzerland, started the ball rolling back in 2018 by petitioning the FDA for a “qualified health claim.” They sent lots of studies with their petition, along with various sample claims they felt were justified by the studies. One sample:

Daily consumption of at least 200mg of cocoa flavanols per serving may reduce the risk of cardiovascular disease. FDA has determined that the evidence is supportive, but not conclusive, for this claim.

That last sentence is common on qualified health claims and implies there’s something positive in the food, but more evidence is needed to say anything stronger.  So the FDA adds a caveat.

FDA: Do It Our Way

The FDA doesn’t really “allow” a qualified health claim. What they do is “consider exercising its enforcement discretion”.  Sometimes this is called a “no-objection” letter.  They don’t endorse the statement, but they won’t bother you if you make a claim – as long as it’s the exact wording they do approve.

The FDA’s response didn’t agree with ANY of Callebaut’s statements on chocolate or cocoa powder.  They said there wasn’t enough solid evidence to make claims about dark chocolate.  They felt more comfortable with a statement on cocoa powder, but completely nixed Callebaut’s requested claims, substituting 4 of their own (see page 18 of the FDA document). One of these approved statements:

“Very limited scientific evidence suggests that consuming cocoa flavanols in high flavanol cocoa powder, which contains at least 4% of naturally conserved cocoa flavanols, may reduce the risk of cardiovascular disease.”

Not exactly a ringing endorsement. 

         “Dutched” cocoa (left) won’t get the claim

The FDA specifically noted “at least 4% of naturally conserved cocoa flavanols”, to prevent just any cocoa powder from making the claim.  Dutch-process cocoa, a.k.a. “cocoa processed with alkali” (the dark powder on the left in the photo) could not make the claim, for instance, as this process eliminates most of the flavanols .  The FDA also likely wanted to prevent makers from just adding additional flavanols to their cocoa powder, in order to be able to make the claim.  This phrase in the statement will prevent that.

Callebaut, and any other producers of this type of cocoa powder, can now use any of the 4 approved claims.  Callebaut is one of the largest however, so they stand to benefit the most.

Would A Company WANT to Make This Claim?

That remains to be seen.  The claim is long, wordy, and has qualifiers that water it down. My guess is that Callebaut wanted to be able to make SOME kind of health claim about SOME kind of chocolate, to give it more of a health halo.

All of the FDA’s approved statements acknowledged that there appears to be some good stuff in that cocoa bean, but a stronger claim will require more research — and the funding to get it done. 

We’ll see if any of the big brands are up to the challenge.

Featured image: congerdesign from Pixabay