Guide
Allergens in dark chocolate
Dark chocolate very often contains soya lecithin. It is not automatically milk-free: some dark chocolates contain milk, and some do not. Cocoa butter is not milk. Read the specification before you call a brownie dairy-free.
Reviewed against official guidance.SourcesNot legal advice.
The usual pattern
A typical bar is cocoa mass, sugar, cocoa butter and an emulsifier. The emulsifier is the usual surprise. If it says soya lecithin, emphasise soya. If it says sunflower lecithin, soya drops off the label.
What to check in dark chocolate
| What you see | What it means on a PPDS label |
|---|---|
| Soya lecithin | Soya |
| Milk or butter oil in some dark chocolates | Milk |
| Cocoa butter | Not milk |
| Sunflower lecithin | Not soya |
How to write it on the label
PPDS food needs the name of the food and a full ingredients list, with the 14 allergens emphasised every time they appear. The Food Standards Agency’s PPDS guidance is the practical reference. A typical ingredients fragment looks like this — yours must follow the specification of the product you actually use.
Example fragment
Cocoa mass, sugar, cocoa butter, emulsifier: soya lecithin.
Where it shows up
Brownies, cookies, ganache, muffins and dessert pots.
One chocolate for every recipe
The 70% you use in January and the cooking chocolate you use when you run out are often different allergens. Keep both specs.
Milk chocolate always contains milk, and usually soya as well. Do not copy a dark-chocolate label onto it.
Specification first
Brands differ. Treat this page as the usual pattern, then match the label to the tub, bag or recipe in front of you.
Questions
Is cocoa butter milk?
Do I emphasise 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.
- Introduction to allergen labelling for PPDS foodFood Standards Agency / GOV.UK
- Labelling guidance for prepacked for direct sale (PPDS) food productsFood Standards Agency / GOV.UK
- Food allergen labelling and information requirements technical guidanceFood Standards Agency / GOV.UK