White baking chips sit next to the chocolate chips and look like part of the same family, yet the product names for two brands’ white chips stop short of calling them chocolate. Giant Food Stores lists Ghirardelli’s as Classic White Vanilla Flavored Baking Morsel Chips, and Stop & Shop lists Nestlé’s as Toll House Premier White Baking Morsel Chips. Neither product name includes the words “white chocolate,” and the ingredient list shows why the name could not be white chocolate on its own: cocoa butter never appears.
What the federal rule requires before a label can say “white chocolate”
White chocolate has had its own federal standard of identity since the Food and Drug Administration published a final rule on October 4, 2002, which took effect on January 1, 2004, according to the FDA’s compliance guide for the rule. The standard came from separate petitions by Hershey and the Chocolate Manufacturers Association. Before it existed, a company that wanted to sell a product called “white chocolate” had to apply for a temporary marketing permit, and the rule notes that the FDA received more than a dozen of those requests in a single year.
The standard itself, 21 CFR 163.124, describes white chocolate as cacao fat mixed and ground with dairy ingredients and sweetener, and it sets these four numbers by weight:
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At least 20 percent cacao fat, which is cocoa butter.
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At least 14 percent total milk solids.
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At least 3.5 percent milkfat.
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No more than 55 percent sweetener.
The rule also says white chocolate has to be free of coloring, and it caps emulsifiers at 1.5 percent and whey at 5 percent. The four main numbers are the same ones Hershey and the trade group described in their petitions, and the FDA wrote that the standard lines up with the white chocolate rules in Canada, the European Union and the international Codex standards.
In the Federal Register notice, the FDA explained that products named “chocolate” have traditionally contained cacao-derived ingredients, so shoppers expect them there, and that the standard will make sure products sold as white chocolate contain cacao-derived ingredients. White chocolate is made without the nonfat part of the cacao bean, so cocoa butter is the only cacao ingredient in it.
What the white chips use instead
The ingredient list for the Ghirardelli white chips reads sugar, palm kernel oil, whole milk powder, nonfat dry milk, soy lecithin and vanilla extract. The Toll House Premier White morsels list sugar, fractionated palm kernel oil, milk, nonfat milk, hydrogenated palm oil, soy lecithin and natural flavor. Palm oils take the place cocoa butter would hold, and with no cacao fat in the bag, neither product can meet the 20 percent minimum.
Ghirardelli also sells a product labeled white chocolate. Its White Chocolate Baking Bar lists sugar, cocoa butter, nonfat dry milk, milkfat, soy lecithin and vanilla extract, with cocoa butter second. One brand makes both items, and both sit in the baking aisle, so reading the front of the package and the ingredient list is the quickest way to tell which one is in the cart.
Why the chips can be the better pick for bark
In a 2017 piece on white chocolate versus white baking chips, America’s Test Kitchen explains that melting white chocolate changes the crystal structure of its cocoa butter, so unless that structure is rebuilt, the white chocolate sets up soft instead of firm. White baking chips, the test kitchen found, harden again into a firm, snappy form without any extra steps.
When America’s Test Kitchen tested a fresh fruit tart, fillings made with bars of white chocolate were too loose to slice neatly and could not hold the fruit in place, while fillings made with white baking chips set up well. In bark, white chocolate gave a soft texture closer to a truffle, and white chips gave the firm snap bark is supposed to have. The test kitchen’s advice is to use whichever one the recipe calls for, because swapping one for the other changes the result.
That makes the label worth reading before a batch of holiday bark. When a recipe names white chocolate, the bar with cocoa butter in its ingredient list is the match, and when it names white chips, the bag of chips is.
Where white chips or white chocolate show up on Real Balanced
The skillet chocolate chip cookie bakes in a preheated cast-iron skillet at 350°F for 20 to 25 minutes and gets scoops of vanilla ice cream on top. The recipe uses semi-sweet chips, and one of its listed variations swaps them for white chocolate chips with a handful of chopped macadamia nuts.
The Lucky Charms Rice Krispies treats are pressed into a 9×13-inch pan and cooled for about 45 minutes before slicing. One of the variations on the recipe is a drizzle of melted white or milk chocolate over the cooled bars.
