Brazil Enacts Law to Raise Cocoa Minimums and Require Front-of-Pack Labels on Chocolate

Overview

• The new law, published Monday in the federal gazette, applies to domestic and imported products and gives companies 360 days to change recipes and packaging.
• Packages must display the phrase “Contém X% de cacau” on the front panel in a field that covers at least 15% of the main area with clear, high-contrast text.
• Core standards rise across categories: chocolate must have at least 35% total cocoa solids with minimums for cocoa butter and fat-free cocoa, milk chocolate 25% cocoa and 14% milk solids, chocolate powder 32% cocoa, white chocolate 20% cocoa butter and 14% milk solids, and achocolatados or coverings 15% cocoa or cocoa butter, and shells or residue cannot count as cocoa; the law also ends the “amargo” and “meio amargo” labels.
• Items that fall short of the new formulas cannot use images, colors, or terms that could make buyers think they are chocolate, and violators face penalties under Brazil’s Consumer Defense Code and sanitary rules.
• The government will still set technical methods for measuring cocoa and for enforcement in upcoming regulation, as cocoa growers welcome likely gains in transparency and demand while industry group Abicab warns the definitions could limit innovation and seeks changes in that phase.