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Example label

Millionaire’s shortbread label example

Millionaire’s shortbread is three layers and several mentions of milk. The shortbread is wheat and butter. The caramel is condensed milk or butter and sugar. The chocolate topping usually contains soya lecithin.

Reviewed against official guidance.SourcesNot legal advice.

The label

Ingredients (teaching narrative)

Wheat flour, butter (milk), sugar, condensed milk (milk), butter (milk), dark chocolate (soya lecithin).

  • Wheat — shortbread
  • Milk — butter and caramel, emphasised every time
  • Soya — chocolate emulsifier

What this teaches

Condensed milk is milk. Emphasise milk in the butter and again in the caramel.

Is this PPDS?

Bars wrapped before they go on the counter are PPDS. Pieces on an open tray are loose food.

Questions

Is caramel milk?
A caramel made with condensed milk, butter or cream is milk. A recipe that is only sugar and syrup is not.
Can I skip soya if the chocolate is dark?
Only if that chocolate’s emulsifier is not soya. Many dark chocolates use soya lecithin.

Official sources

Everything on this page traces back to these. Where they and we disagree, they are right — tell us and we'll fix it.

Typical sectors: Bakeries.