In India an Ice Cream can't be called an ice cream unless it has a minimum of 11% fat (aprox) which is why Nirula's called its Sorbets "fozen fruit desserts" instead of Ice Cream. Similarly in United States, you can't call your product a "chocolate" if you have used vegetable fats instead of Cocoa butter and artificial sweeteners. In 2007, Hershey's wanted to do exactly that and with other manufactures which make up the Chocolate Manufacturers Association in the United States, it lobbied the Food and Drug Administration to change the legal definition of chocolate so they get away with using partially hydrogenated vegetable oils for cocoa butter in addition to using artificial sweeteners and milk substitutes but it was not approved.
However, in 2008, Hershey went ahead with that and reformulated its products to replace cocoa butter with vegetable oil as an emulsifier. Some consumers complained that the taste was different, but the company stated that in the company-sponsored blind taste tests, approximately half of consumers preferred the new versions. Now this is how you twist the truth. The truth is that people were able to "tell" the difference between the two.
Since the new versions didn't met the Food and Drug Administration's official definition of "milk chocolate", the changed items were relabeled from stating they were "milk chocolate" and "made with chocolate" to "chocolate candy" and "chocolaty." A good FDA should have stopped a company from playing with words like this.
These wrappers read milk chocolate. Does this mean that these have cocoa butter or does this mean that the FDA regulation doesn't apply to what a company exports?