CMA - Chocolate Manufacturers Association
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Standard of Identity (SOI) Educational Paper

The proliferation of new confectionery products with "chocolate" coatings, chips, and chunks made from ingredients other than nutritive carbohydrate sweeteners (sugars) and "sugar free" claims has prompted a number of questions by our membership. There appears to be a wide variety on how these products are labeled in the trade. The purpose of this document is to provide CMA’s current understanding of how these products should be labeled.