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Confusion over food watchdog's rule barring sales of "raw chocolate" products

The term "raw" cannot be used for chocolate sold in Finland, nor can products be labelled "raw chocolate" in English.

Suklaa hylly Itäkeskuksen Ruohonjuuri myymälässä
Raw chocolate products on display at Ruohonjuuri's Itäkeskus outlet. Image: Antti Kolppo / Yle

Chocolate companies are stewing over a decision by the Finnish Food Authority (formerly Evira) to prohibit the sale of products labelled "raw chocolate". The term has no formal definition but is generally believed to mean chocolate made from cocoa beans that have not been roasted.

In a statement on its website, the food agency provides a list of terms that can be used for the sale and marketing of chocolate and cocoa products. However it notes that the term "raw chocolate" is not to be used to describe any chocolate products sold in Finland.

"Raw chocolate as a food product name is an ambiguous term that could mislead consumers," the agency's senior officer Tuulikki Lehto said in the guidelines.

However some chocolatiers said that the authority’s ruling on the matter has come as a complete surprise, given that they believe the term has become an established expression that has already been in use for several years.

For example the organic and sustainable products chain Ruohonjuuri has offered consumers many different kinds of raw chocolate goods for decades. Its product offering currently includes 150 raw chocolate products.

"We believe that raw chocolate has become an established term and it accurately describes the product: chocolate that has been prepared using products that have not been heated," Ruohonjuuri purchasing manager Jussi Aimola commented.

Maria Jalkanen of the family-owned firm Foodin Rawmance also said she considered "raw chocolate" to be a recognised term. The Jyväskylä-based company manufactures and imports organic products and its selection includes more than 30 types of raw chocolate items.

Jalkanen said that instead of prohibiting sales of products carrying the raw chocolate moniker, she would have liked the agency to define it.

"We could have borrowed from the example of the rest of the world where the market for raw chocolate is large. Of course I listen to domestic customers, among whom many established users already have a clear impression of what goes into raw chocolate and what doesn’t," Jalkanen added.

Term not officially defined by EU

The Food Authority decided to weigh in on the issue of the use of the term after receiving complaints and enquiries from consumers and entrepreneurs. It said that the new guidelines aim to improve consumer protection.

"If no one knows what is really meant by the term raw chocolate, then consumers cannot make informed choices," Lehto declared.

She added that another problem with the term is that it has not been officially defined by the EU. The authority concluded that there is no international consensus on what makes chocolate raw chocolate. For example, there is no universal understanding of how raw chocolate should be handled during manufacturing or what kind of raw material or ingredients should be used in it.

"The legislation does not recognise the term raw chocolate. And as far as I know it is not being defined at the EU level," Lehto explained.

The upshot is that specifically, the term "raw" cannot be used to describe chocolate sold in Finland. The prohibition applies to products manufactured in Finland as well as to imported goods. In addition, the English-language "raw chocolate" cannot be used locally.

Sami Nupponen, CEO of Goodio chocolate factory in Helsinki, said that he understands the official line. "It’s normal for officials to define the terminology to be used. There should be common criteria for raw chocolate so that it can be taken into common use," he noted.

Name change may affect buying decision

Chocolate entrepreneurs predicted that banning the use of the term will create headaches for consumers.

"It will of course be somewhat challenging for consumers who prefer raw food when the term used for a familiar product disappears," Nupponen remarked.

Ruohonjuuri’s Aimola noted that customers are already upset over the removal of the category. He said that the decision to prohibit the naming convention will make the purchasing decision difficult for consumers.

"Now they cannot easily know which chocolates are raw and which have been manufactured using conventional methods."

The Finnish Food Authority’s Lehto countered that there is nothing to prevent producers from describing their products’ manufacturing methods on the packaging. She also pointed out that chocolate industry firms can lobby the EU to define the term.

The agency’s ruling means that importers and producers of chocolate products will have to modify product packaging and labels. Foodin Rawmance’s Jalkanen said that the family firm is still working on making the required changes.

"The product name change is confusing customers, so the biggest job is getting the information out that a product’s recipe or manufacturing methods have not changed," she concluded.

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