Dark chocolate and dairy milk cross contact - 4 June 2019

Dark Chocolate


Allergy & Anaphylaxis Australia (A&AA) is aware that many consumers with cow’s milk allergy presume that dark chocolate is a safe chocolate for them to eat as milk is generally only mentioned in the precautionary allergen labelling statement and not in the ingredient list.   

A&AA is notifying consumers with milk allergy that some (dark) chocolate manufacturers are changing their labels to list milk allergens in the ingredient declaration. The industry’s rationale is to ensure the best protection for consumers with cow’s milk allergy. 

Milk may be listed as the last ingredient because it is often unintentionally present at levels that can trigger allergic reactions, including anaphylaxis, and these levels are higher than those normally associated with labelling in a precautionary allergen statements (e.g. a ‘may contain’ / ‘may be present’). Typically, in these cases, ‘milk’ will be listed as the last ingredient, even though the milk is not an intentionally added ingredient.

The reasons that some Australian and New Zealand dark chocolate manufacturers are making this change is that dark chocolate is often made on the same production line as milk chocolate. Australia and New Zealand are small scale markets and therefore dedicated dark chocolate equipment and production lines are not commercially feasible.

From a hygiene and sanitation perspective and given the incompatibility of chocolate and water-based cleaning processes, cleaning requires scraping production equipment down or flushing with liquid dark chocolate product. 

Factory systems and piping are also not always accessible for cleaning, so residual milk chocolate may remain above a precautionary allergen labelling level.  Such milk residue may be higher at the beginning of a milk to dark production changeover, milk levels may also fluctuate from the initial batches and deplete over time as production continues. 

These labelling changes are being implemented by some dark chocolate manufacturers to provide consumers with cow’s milk allergy the information that they need to make an informed decision when purchasing dark chocolate.

A&AA and Allergy New Zealand are aligned and support this industry initiative to ensure the best protection of consumers with cow’s milk allergy.

Importantly, we also encourage consumers and their carers to be vigilant to ingredient information and make it their practise to check labels every time a product is purchased. During the transition period some dark chocolate products will contain milk as a last ingredients and others will not. Please presume all dark chocolate contains milk, no matter what the label says, during this change to safer labelling for those with cow’s milk allergy.  If you have any queries, please check directly with the chocolate manufacturer as your favourite dark chocolate product may fall outside the scope of this issue.

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