Ever had cheap, waxy chocolate--the kind that doesn't melt in your mouth so much as cling to your teeth? That texture was probably caused by vegetable fat, and if a few trade associations get their way, manufacturers could eventually have the option of labeling such mockolate as "chocolate."

This April, the Grocery Manufacturers Association (GMA) introduced a citizens petition encouraging the FDA to update the standards of identity for various foods. One of those foods is chocolate, and one of the co-signers of the petition was the Chocolate Manufacturers Association (CMA), a trade group representing major chocolate producers such as Hershey, Nestle and Mars. (Not all CMA members support the petition.)

Currently, the FDA standards of identity for chocolate state that it must contain at least 23.27 percent cocoa butter, and that it cannot contain any vegetable fat. The proposed standard change would allow up to the same percentage of vegetable fat. Currently, such cocoa-butter-free products must be labeled under names such as "chocolate coating" or "compound chocolate."

Chocolate as we know it is not in danger. It could take up to a decade or more for the changes proposed in the petition to go into effect, and those changes won't force chocolate manufacturers and confectioners to change how they make chocolate; it merely gives them the option to change their formulas.

So why all the fuss? Cocoa butter is a unique fat. According to Harold McGee's book On Food and Cooking, it "gives the impression of cooling the mouth as it melts because its melting point is just below body temperature, and the phase change from solid to liquid absorbs energy without raising the temperature of the fat." In other words, replacing some or all of the cocoa butter in chocolate with vegetable oil will greatly change the pleasure of the eating experience.

It also changes the cost. Cocoa butter ($2.30 a pound) is more expensive than vegetable oil (70 cents a pound). And it is more sensitive to temperature, which means chocolate needs to be shipped in a temperature-controlled environment to maintain its texture and appearance. In confectioner's terms, vegetable oil is cheaper and a lot less finicky.

The issue has struck a chord for several reasons, least of all that chocolate lovers are very protective of the object of their desire. "It's so confusing to the consumer," Fran Bigelow of Seattle-based Fran's Chocolates recently said on NPR's Talk of the Nation. "They're asking to know what's in their food, and they're searching out pure foods in all matters. . . . I think the label 'chocolate' should be chocolate."

"The wine industry finally are getting their laws passed to say if the grapes aren't from Napa, [wine] can't say 'Napa' all over it," says Mary Stornetta of Anette's Chocolates in Napa. "But [the petition] is one more way for people to market something as what it's not in order to profit more."

Stornetta says that if changes did happen, it would have little impact on small confectioners like Anette's. "Even if the law did go through, we wouldn't use lesser-quality items, because that's not what we do. The people who buy from us are the people who want the really good, quality chocolate. So in a way, it would help us and make our product shine more. You get what you pay for."

If anything, this whole debate should remind us that scrutinizing a product's ingredients listing and nutrition information, rather than taking its label at face value, is the best way to know what we are putting into our bodies.

The FDA has extended the consumer comment period on the petition until June 25. To register a comment with the FDA, visit www.dontmesswithourchocolate.com. To learn more about the CMA's perspective, go to www.chocolateusa.org.

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