The federal Food and Drug Administration is considering if it will allow chocolate makers to substitute vegetable oil for cocoa butter - but still legally label the resulting product "chocolate."

In October, The Grocery Manufacturers Association gave the U.S. Food and Drug Administration an innocuous-looking wish list. It asked the FDA to relax its restrictions on the listing of ingredients and labeling for certain products.

Most of the food manufacturers' requests were sort of bland. They asked the FDA to green-light adding an anti-fungal ingredient to bulk cheese (not a bad idea, actually) and to OK adding powdered milk to yogurt. But the lists also included this bombshell: "to use a vegetable fat in place of another vegetable fat named in the standard (e.g. cocoa fat) …"

Chocolate enthusiasts reacted quickly. Their basic position: Substituting vegetable oil for cocoa butter in chocolate and still calling it "chocolate" was a lot like subbing vegetable oil for the cream in butter, then selling it as butter.

Cocoa butter is a prime ingredient in chocolate. If you prefer white chocolate, you're primarily eating cocoa butter, milk solids and sugar, which suggests to us that you can take the cocoa and chocolate liquor out of chocolate and still call it chocolate, so long as you have the cocoa butter.

Regina Hildwine, the senior director of food labeling and standards for the grocery manufacturers, tried to justify the change as necessary to innovation.

Really? Because it sure sounded like the food manufacturers are trying to perpetrate a bait-and-switch scheme by subbing cheap fats for the real thing. This is a truth-in-

advertising issue as much as preserving our understanding of what defines basic chocolate, which is stuff that we love.

Depending on which consumer organization you quote, the average American eats between 11.7 and 25 pounds of chocolate a year. We've eagerly gobbled up everything from classic chocolate bars (still the leading favorite) to chocolate-covered potato chips and even wasabi-flavored bonbons.

If the grocery manufacturers and chocolate manufacturers want to start making chocolate with olive oil or sesame oil and calling it something clever like "savory sweetness," hey, that's OK by us, too. Just price it and label it accordingly.

We're not alone in this view.

Since October, the FDA reports an overwhelming negative public reaction to expanding the definition of what can be

labeled as chocolate.

If your own view is "If it looks like chocolate, smells like chocolate, feels like chocolate and tastes like chocolate, who cares what's in it?", you'll find like-minded views at www.chocolateusa.org. (Watch for the bland cleverness that both endorses the change and seeks to minimize its impact).

If you think that you don't mess with the good stuff in life, let the FDA hear your views at http://dontmesswithourchocolate.

guittard.com.

No fence-sitting, please! The future of our nation's favorite candy is at stake.