Could Dairy-Free Dark Chocolate Still Trigger Milk Allergies?

After conducting a limited survey of dark chocolate products for the presence of milk, the U.S. Food and Drug Administration (FDA) has issued a consumer update that the organization hopes will provide a snapshot view of the presence of undeclared milk in dark-chocolate products.

The FDA tested 94 dark chocolate products—6 containing milk or milk-derived components in the ingredient list, while 88 products were not explicitly labeled as containing milk, i.e., did not have milk in the ingredient statement or in a “Contains” statement.
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Based on the agency’s findings, some of which were released earlier this year, the FDA says the ingredients list does not always indicate whether a dark chocolate product contains milk. Of the 88 dark chocolate bars tested that did not list milk as an ingredient, the FDA found that 51 of them actually did contain milk.

According to the FDA, these findings can be attributed in part to the fact that milk can get into a dark-chocolate product even when it is not added as an ingredient. Most dark chocolate, the agency notes, is produced on equipment that is also used to produce milk chocolate. In these cases, it is possible that traces of milk may inadvertently end up in the dark chocolate, according to the FDA.

From a consumer standpoint, one should not assume that dark chocolate contains no milk if the label does not mention it, and milk-allergic consumers should be aware that 33% of the dark chocolates with no mention of milk on the label were actually found to contain milk, according to the FDA, which is evaluating the study findings and considering options for addressing the issues identified in the survey.

The agency advises consumers to be aware that dark-chocolate products are a high-risk food for those who are highly milk-allergic; to check ingredients lists; to read all label statements on dark-chocolate products and avoid those with an advisory statement for milk; and view even those products claiming to be dairy-free or without any mention of milk with caution.

For primary care physicians confronted with a milk-allergic consumer who claims to have eaten dark chocolate in the past without issue, “the recommendations are much more difficult, as one would not want to potentially scare off individuals from eating a food that they enjoy and have little risk for reaction,” notes FDA Spokesperson Jason Strachman Miller.

“Physicians should know that the reaction risk is highest for ‘highly sensitive’ milk allergic individuals,” adds Strachman Miller.

“This means that it is possible that some patients have very high thresholds to milk, and would thus not be at risk for reacting to exposures to a lot of these products.” Thus, he says, recommendations would need to be made on a case-by-case basis, depending on the patient’s known tolerance and/or history and severity of reactions to milk in the past.

“Even with this reaction history information, most primary care physicians do not have the tools to determine who is high-risk,” he says, adding that referring these patients to an allergist “is another consideration for primary care physicians.”

—Mark McGraw