Raw chocolate is not legally defined, but manufacturers typically say their products have not been exposed to temperatures exceeding 42°C, often meaning that the cocoa beans have not been roasted. It is perceived that these conditions help to maintain healthy nutrients such as flavanols in the cocoa.
But the NCA has issued a white paper that says the lack of heat treatment means Salmonella may not be killed in raw chocolate.
“NCA is concerned that finished chocolate products sold as raw may present a health hazard to consumers if a validated process is not used to destroy Salmonella,” it said.
The high temperature cocoa bean roasting process is chocolate manufacturers’ primary method to inactivate bacteria.
The trade body noted several Salmonella outbreaks in the last 30 years, including a 2001 outbreak in Germany and Denmark from chocolate products manufactured by the Storck Group, where inadequate thermal processing was blamed.
‘No more risk than raw vegetables’
The raw chocolate market in the US is still relatively niche, representing less than 1% of new products launched in 2010, according to the NCA, with the majority of products sold over the internet. But it notes that raw foodism is growing in popularity.
Tom Louvel, general manager of UK-based firm The Raw Chocolate Company, said that the risks associated with raw chocolate were overstated.
“There are lots of raw foods out there. Why is raw chocolate more subject to contamination than raw leeks or carrots?” he said.
“If you consider that thoroughly washing raw vegetables may not be enough to get rid of Salmonella in all its forms, then you end up with scenario similar to that of raw cacao i.e. there is no 99% kill procedure available as of yet. Does this mean that consumers should stop eating raw cacao and raw vegetables altogether?”
He said the company carried out batch tests to guard against the presence of Salmonella and ensured that manufacturing procedures and cleaning did not use any water in order to curtail the spread of pathogens. “There’s only so much you can do,” he said.
The NCA’s white paper said that salmonella could survive in low moisture foods and could live from months to years in chocolate.
We asked Susan Smith, executive director of chocolate at the NCA, if it was possible to make raw chocolate without roasting and still eliminate Salmonella.
“Theoretically there are a number of different ways that chocolate making processes could validate adequate killing of salmonella without roasting. Technologies used by other industries to sterilize food ingredients include irradiation and chemical treatments, though we’ve not heard of these techniques being used on cocoa.”
Smith said that the FDA’s Food Safety Modernization Act preventive controls rule, would soon require all raw chocolate producers in the US to introduce preventative controls.
“Since Salmonella is an inherent risk for cocoa, once this rule goes into effect, all manufacturers will be required to have controls in place to eliminate salmonella,” she said.
Asked if the NCA statement could affect the Raw Chocolate Company’s business, Louvel said: “We will have to see the impact. It could be damaging, but we are not feeling any repercussions yet.”
“The idea is that because you process it minimally you keep the enzymes and nutrients. Research, if any, is at the embryonic stage. There are indications that there should be more, but science can’t say at the moment.”
“The extent to which flavanols (and particularly biologically relevant flavanols) decrease via processing is challenging to measure because the analytical methods used to determine this vary from study to study. Many factors influence the final flavanol concentration in a product, so we cannot simply say that processing reduces flavanol content by a certain per cent.”
Contamination at farm level
Salmonella is the primary pathogen concern for cocoa and contamination begins at farm level.
“Due to the difficulty in controlling the conditions on the farm, all raw cocoa as a commodity is considered potentially contaminated,” said the NCA’s white paper.
Cocoa beans are often left to ferment for several days in heaps covered with banana leaves in order to develop flavor. After fermentation, the beans are dried, typically in large open-air racks.
Under both procedures the beans are exposed to air, birds, insects, humans and animals, creating a risk of contamination.
“While the fermentation step may generate temperatures as high as 51.7°C (125°F), these conditions will not inactivate pathogens, if present,” said the NCA.