Ingredient
Cocoa butter
A fat named after an animal product it has never contained, permitted as a drug at strengths most ingredients never reach, and shadowed in food by a legally defined stand-in.
- INCI name
- Theobroma Cacao (Cocoa) Seed Butter
- Also on labels as
- Theobroma cacao seed butter, Theobroma oil, Cocoa butter substitute
- Found in
- cosmetics, food
Part of Eczema and atopic skin · Animal ingredients
The name does the damage. Cocoa butter is pressed from the cocoa bean and has never contained milk, but it is the word butter that people read, and it is the reason the question keeps being asked.
No dairy, and the regulation never suggests otherwise
There is no milk in cocoa butter. Where a chocolate raises a genuine dairy question it is because of milk solids listed separately, not because of the fat. What “non-dairy” does and does not promise covers where that goes wrong on a label.
The strength that stands out
The skin protectant monograph permits “Cocoa butter, 50 to 100 percent”.
Almost nothing else on that list runs so high. Allantoin is capped at 2 percent, kaolin at 20, Calamine at 25. Cocoa butter joins Petrolatum and mineral oil in a small group permitted to be most or all of the product, because what they do they do by being the barrier rather than by acting on the skin.
That has a labelling consequence the regulation spells out. There is a reduced set of requirements for “Products containing only cocoa butter, petrolatum, or white petrolatum”, on the reasoning that a single-ingredient barrier product has less to explain than a multi-active one.
The substitute is a legal category, not a euphemism
In food, cocoa butter has an officially defined understudy. The additive regulation opens: “The food additive, cocoa butter substitute from coconut oil, palm kernel oil, or both oils, may be safely used in food in accordance with the following conditions”.
This is one of the clearest cases on the site of a label telling the truth in a way that most readers will not decode. The substitute is not hidden and not mislabelled. It is named, and the name is a term of art that reads like a description.
For anyone avoiding Palm oil specifically, that matters more than the dairy question does, because the substitute is where palm kernel oil enters a product that appears to be about cocoa.
What to actually look at
On a cosmetic, cocoa butter high in the list is doing barrier work and the product may or may not be making a drug claim about it. On a food, read past the front of the pack: the fat is named in the ingredient list, and cocoa butter and cocoa butter substitute are different entries there for a reason.
Sources
- 21 CFR 347.10: Skin protectant active ingredients US Food and Drug Administration, via eCFR · ecfr.gov Permits cocoa butter at 50 to 100 percent as a skin protectant active ingredient.
- 21 CFR 347.50: Labeling of skin protectant drug products US Food and Drug Administration, via eCFR · ecfr.gov Sets a reduced labelling requirement for products containing only cocoa butter, petrolatum or white petrolatum.
- 21 CFR 172.861: Cocoa butter substitute from coconut oil, palm kernel oil, or both oils US Food and Drug Administration, via eCFR · ecfr.gov Defines a cocoa butter substitute made from coconut and palm kernel oil as a food additive with its own conditions of use.