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Cross contamination risk – dark chocolate and dairy milk chocolate

Allergy & Anaphylaxis Australia (A&AA) is aware that many people with cow’s milk (dairy) allergy think that dark chocolate is a safe chocolate for them to eat as milk is generally only mentioned in the Precautionary Allergen Labelling (PAL) statement and not in the ingredient list.  

Some dark chocolate manufacturers have changed their labels to list milk last in the ingredient list. Milk may be listed as the last ingredient because it is often unintentionally present at levels that can cause allergic reactions, including anaphylaxis, and these levels are higher than expected with labelling in a PAL statement (e.g. a ‘may contain’ / ‘may be present’).

This labelling change has been made by some dark chocolate manufacturers to give people with cow’s milk allergy and their carers the information they need to help them decide on the safety of the dark chocolate.

Milk can be present in high levels because dark chocolate is often made on the same production line as milk chocolate.

For hygiene and sanitation reasons and given that water cannot be used to wash equipment that makes chocolate, cleaning requires scraping equipment down or flushing with liquid dark chocolate product.

Factory systems and piping are also not always accessible for cleaning, so small amounts of milk chocolate may remain above a PAL level.  Levels of milk may be higher at the beginning of a milk to dark production changeover and decrease over time as production continues.

A&AA advises people to check the food label of packaged food at least three times

  1. When buying the food 
  2. When unpacking the food at home 
  3. Finally, before eating, drinking, or using the food in cooking

Please expect that all dark chocolate contains milk, unless it is labelled “milk (dairy) free”.  If you have any questions about the product, please contact the chocolate manufacturer.