Hotel Chocolat and the milk-free ‘milk’ chocolate that may not be

Hotel Chocolat have some ‘milk-free ‘milk’ chocolate’ products – flavoured with almond not milk – which many milk allergic or intolerant consumers, and parents of, took to mean ‘milk allergy safe’ – and bought them.

For reasons which aren’t yet precisely clear, on Thursday (I believe), HC began to email those who’d bought the chocolate online ‘a note to clarify the dietary status’ of the products.

“ … no milk is added to the recipe, however our factory environment does use dairy products and there is always a risk of traces of dairy, making this product unsuitable for anyone with a specific dairy allergy”

This came to my attention on Good Friday morning, thanks to @MrsAitchBee, who posted the email on her Twitter feed. A few other social media users were expressing concern. I called the FSA emergency line (shared with DEFRA, I believe), and was told they could not do anything to help. “Keep the chocolate and call Trading Standards on Tuesday” was all they would tell me.

With HC barely engaging on the subject on Friday on social media, and failing to put out a Twitter or Facebook post, and with the charities apparently on Easter break, it was left to allergy parents and advocates to spread the word – which they did, brilliantly, of course.

This has continued today, Saturday, and HC have finally issued social media posts, and begun to engage more with concerned parents – though many feel that this has come just a little late, and is lacking somewhat in urgency.

Here is their message, which also summarises the action they have taken.

Predictably, Twitter and Facebook have been abuzz with the mix of emotions that you might expect, and by now may well be used to, when any alarming or controversial allergy ‘event’ plays out within its virtual walls.

But among the concern and the warming way the allergy community is looking out for its kin, there appear to me to be three misconceptions or uncertainties about this episode, and it’s important we get it right, and not base our communications on their being known fact.

a/ The ‘milk free milk’ product contains dairy.
Hotel Chocolat haven’t explicitly stated this yet, and we don’t know that it has been tested or demonstrated to have milk protein in it. As far as I can tell, HC have said there’s a *risk* it may contain traces.

b/ The HC labelling is illegal.
I’m not sure it is (at least not in the way many are taking it to be). ‘May contain’ labelling is voluntary, not regulated. HC have made a claim – milk free – which may or may not be true. They now appear to have lost confidence in this, for reasons we’re not fully clear about. Perhaps a test result came in, perhaps they belatedly realised the intended ‘may contain’ warning was omitted, perhaps a reaction was reported to them privately. We can’t guess yet…

c/ Children have been made sick by the chocolate
There have been reports on social media about this, but it’s important not to jump to conclusions or make accusations, as some are making. We can’t know for sure, again – not until the time comes (if indeed it comes) when we do know the full facts.

Not to mitigate the seriousness of all this, but it may be worth remembering that recent research suggests that the risk of ‘may contain’-labelled products containing the allergen is generally quite low. (Although dark chocolate containing milk does happen to be one of the more common problems.)

Until we know more, let’s continue to spread the word about the HC recall – if it can be called that – as best we can, so that we further minimise any risk to milk allergy kids.

Edited to add: The Food Standards Agency have, Saturday afternoon, issued a withdrawal notice on the products


  1. Emma Louise

    Thank you for tackling this subject with a clear and calm approach. I have been annoyed with this whole saga. As I can gather the original concern was stimulated by a parent who emailed HC to check the finer details of their processes. The response from HC prompted the parent to be concerned the chocolate was not safe and the media back lash ensued.
    I am the first to demand correct labelling and I can see how some people may have been mislead by the milk free milk claim. However, surely as consumers in control of our own safety we should be cautious of any HC chocolate product likely to be made in the same factory as other HC product lines.
    I can state that I have bought the milk free milk Easter egg and have had no adverse reaction. This is a judgement I have made myself in assessing whether this range meets my dietary requirements.
    I feel sad that a large company trying to provide a new product is getting such venom when they did not intend to harm people.

  2. Alex G

    Thanks Emma. Do we know who the parent spoke with at HC? Has it basically 'kicked off' from just that one parent / phone call? Because a conversation with someone not intimately aware of x-contamination issues in factory, for example, could easily trigger concern if not used to allergy issues.
    It's concerning because HC said that they took advice from Trading Standards on this matter. Have we ruled out that all this has been caused by mere panic, I'm wondering?


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