The Chocolate Lobby

Chocolate has become an essential part of American life, through seasonal and holiday

marketing, baking (as an ingredient, topping, or decoration), and everyday consumption. It was a
 1

popular drink in the colonies, often used as a calming mechanism or to improve digestion. Solid

chocolate only emerged in the mid-19th century with a chalky, unpleasant texture, and people

didn’t prefer eating chocolate to drinking it until around 1920, once milk had been incorporated.1

The booming sugar crop paralleled the growth in chocolate consumption, and companies have

reduced the cocoa content to decrease the cost of production. The list of ingredients on most

chocolate products has expanded far past simply cacao, including other additives that increase

chocolate’s shelf life. The supply of chocolate in the U.S. became abundant as new technologies

mechanized many of the traditionally labor-intensive tasks of processing cacao beans, making

chocolate more affordable. The number of chocolate consumers rose rapidly, and it developed

from an expensive luxury to a mass-consumed product.2

U.S. consumers spent $22 billion on chocolate in 2017, which is approximately twelve

pounds of chocolate consumed per person. Mars, Mondelēz International, Hershey, Ferrero, and

Nestlé control a majority of the American chocolate industry, producing the well-known, mass-

market candies that have made chocolate so ubiquitous. 3 Our cravings for chocolate are easily

fulfilled because chocolate is available in excess.

Nevertheless, the recent developments of dark chocolate into a superfood have brought

health-conscious consumers to the chocolate market looking for alternatives to sugar-rich milk

chocolate. Dark chocolate is favorable for its iron, magnesium, and copper contents, and it is

known to act as an antidepressant by releasing endorphins and increasing serotonin levels in the

brain. Dark chocolate also has a higher cocoa content than milk chocolate, so it contains more

antioxidants which can reduce the risk of cardiovascular disease. Dark chocolate made up 27.7

percent of 2016 chocolate revenue, and the consumer preference for premium dark chocolate
 2

over other varieties is expected to continue its upward trend, as Americans' tastes evolve and

more research suggests the health benefits of dark chocolate.4

Without any claims of chocolate being heart healthy or a superfood, flavor is most

important in deciding whether to indulge. Americans are becoming more interested in the flavors

and textures of chocolates with more cacao and less sugar, following the trends of coffee, wine,

and craft beer. Dark chocolate sales grew eight percent in 2014, while premium chocolate sales

grew eleven percent, indicating that the sweetness of milk chocolate may be becoming less

popular than the unique flavors and experiences offered by craft chocolate.5

As the major manufacturers try to adapt to these consumption changes, boutique

chocolate firms have entered the market to fulfill new demands. Producing fine chocolate is an

expensive process with significant barriers to entry for small firms, but enough consumers are

now willing to pay a high price for the final product, so the process can be profitable. Small

firms can afford to purchase ethically sourced cacao to produce their bean-to-bar chocolates

because consumers will appreciate the ethical sourcing and purchase the chocolate they enjoy,

despite the price. Our society is too dependent on chocolate to ignore the suggestion that it could

be good for us beyond making us happy.

I will explore how chocolate producers have acted, separately and in coalitions, on

chocolate regulations in response to this growing demand for fine chocolate. I will first discuss

existing regulations and current regulatory issues that impact the chocolate industry before

describing the philosophies and messaging of large manufacturers. I will then consider the

strengths and limitations of the groups involved in chocolate policy and analyze the strategies

used by companies and their coalitions to create power and impact policy, particularly in

response to the increasing demand not only for fine chocolate, but also for transparent labeling
 3

and healthy products. While small and large chocolate producers seem to work well together in

securing a successful future for the chocolate industry that will continue to provide the chocolate

that Americans want, their individual interests in obtaining that goal do not always align. The

consumers or businesses that desire more transparency from the mass-market manufacturers may

be overshadowed by the dominant corporations in the interest group arena. Nevertheless,

corporate interests have been shifting in ways that may not create new regulations on chocolate,

but could lead to a better industry understanding of and respect for consumers’ interests.

Current Regulatory Issues

As chocolate became a well-known and well-received product, the FDA began to publish

loose regulations to verify the quality of chocolate products and promote transparency about

ingredients and sourcing. The low standards continue to allow for the addition of many

ingredients beyond chocolate liquor. According to Part 163 in Title 21 of the USDA’s Code of

Federal Regulations, milk chocolate is made by mixing chocolate liquor with dairy ingredients

and sweeteners, and it must contain at least 10 percent chocolate liquor, 3.39 percent milkfat, and

12 percent milk solids. Products had to contain chocolate liquor in order to be labeled

“chocolate” until 2002, when Hershey’s and the Chocolate Manufacturer’s Association lobbied

for white chocolate to no longer be considered just a “confectionery.” White chocolate now

requires at least 20 percent cocoa butter (cacao fat), 3.5 percent milkfat, 14 percent milk solids,

and less than 55 percent sweetener.6

While these regulations give the consumer a better understanding of what goes into their

favorite chocolate candies, the FDA does not regulate the identity of dark chocolate.7

Corporations can easily label their products as “dark chocolate” regardless of their cocoa content

to attract health conscious consumers who will pay a higher price for premium products. The
 4

absence of a dark chocolate regulation can lead to greater profits for traditional manufacturers,

rewarding ambiguity.

Hershey’s milk chocolate, for example, contains only 11 percent chocolate liquor, taking

advantage of the lower cost, and Hershey’s Special Dark contains only 45 percent cocoa.

Hershey’s extra dark chocolate reaches 60 percent chocolate liquor, the commonly accepted

minimum for a dark chocolate bar.8 These percentages are not labeled on the packaging because

just the dark chocolate label will attract consumers. Average chocolate lovers convinced that

they should convert to dark chocolate for health reasons could be more likely to purchase brands

they are familiar with, and the lack of transparency on the label may contribute to further happy

(over)consumption of sugary chocolate. Inadequate regulations allow the corporations to

maintain credibility and sustain the competition that might exist between their dark chocolates

and premium dark chocolates. Small-scale firms create luxury products and are incredibly

transparent about their cacao sourcing and cocoa content in order to thrive in the era of health-

conscious, sustainable chocolate consumption. They might prefer greater regulations that would

put the established manufacturers at a disadvantage in maintaining their market share as dark

chocolate demands escalate.

Corporations, Their Messages, and Their Motivations

Mars, Mondelēz International, Hershey, Ferrero, and Nestlé are referred to as the “Big

Five” chocolate manufacturers in the U.S., and they are responsible for shaping the American

people’s views about their beloved candies.9 Hershey’s and Mars, in particular, dominate the

American market, respectively taking 43.8 and 30 percent of the market in 2017, with their

popular candy bars that often showcase flavors such as peanut butter or caramel rather than the

chocolate itself.10 They have incredibly recognizable brand names, and their niches are defined
 5

by the unique products they sell in abundance across the country. According to Squicciarini and

Swinnen, “American manufacturers define success by sales rather than quality,” valuing their

massive market shares rather than a manufacturing process that could provide higher quality

products to their customers.11 Manufacturers’ messages are constantly on display on grocery

stores’ shelves and TV commercials, motivated by profits.

Such large corporations face issues in the interest group arena because they must

maintain their brands by acting in ways that will not polarize the many interests to which they

are accountable, including stockholders, employees, and customers. Major chocolate

manufacturers exemplify how corporate groups want to keep the status quo and prevent the

government from interfering with business by imposing new regulations.12 They already face

standards of identity for milk and white chocolate set by the FDA, but they generally desire

flexibility that allows them to produce more cheaply and maintain their marketing strategies. For

example, a 2007 petition to the FDA co-signed by the Chocolate Manufacturers’ Association

proposed that vegetable oil should be able to be substituted for or used in addition to cocoa butter

in chocolate. Vegetable oil would simply reduce the costs of chocolate production for the

manufacturers, as less cacao lowers the expense. The public comment period allowed Americans

to show their disgust for the proposed change, and no regulations on the fats allowed in

chocolate were loosened in favor of transparency for the public.13 Although the companies are

responsible for creating such passion among chocolate lovers, the passion can also be used as a

check on corporate actions.

The Chocolate Lobbying Community and the Importance of Coalition-Building

Chocolate and confectionery companies are willing to work together to achieve shared

goals because, while one company may be ineffective, a coalition of some of the most well-
 6

known manufacturers in America can be very powerful.14 The National Confectioner’s

Association (NCA) is a trade organization that represents chocolate and candy companies to

“ensure the public understands and appreciates the unique role that chocolate and candy can play

in a happy, balanced lifestyle.”15 Members of the NCA include 320 confectionery manufacturers,

as well as 225 suppliers and 115 brokers, whose interests in the advancement of the industry are

protected by the NCA. Membership dues and levels are determined based on annual company

sales, amassing a large budget. The manufacturers range from Hershey and Mars to boutique

crafters, including firms such as Bixby & Co., the only bean-to-bar chocolate maker in the state

of Maine.16 Organizations that represent such a variety of interests usually refrain from issues

that would create division among members and instead engage in “lowest common denominator”

lobbying, engaging in issues on which the majority of the membership agrees.17 The NCA

focuses its lobbying efforts on updating U.S. sugar policy and reforming the sugar subsidy

program to lower the inflated price of sugar by eliminating production and import limits. It also

advocates for modernization of trade agreements to open new markets for the American

confectionery industry.18 These advocacy efforts benefit a majority of NCA members by aiming

to lower costs of production, spur growth for the companies, and create jobs.

The Grocery Manufacturer’s Association (GMA) has been facing unfortunate

membership retention issues in the past few years, as the goals of the departing members

conflicted with the recent actions of the organization. The GMA represents producers of food

and beverage products far beyond the confectionery industry, but many food producers have

recently left, including Nestlé, Mars, and Hershey.19 The exact reasons for leaving are not public,

but executives have privately noted the inflexibility of GMA management on issues, despite the

consumers’ desires for more transparency on food labels, more sustainable production, and
 7

healthier choices. GMA was unwilling to support companies’ desires to be consumer-friendly in

response to changing demands, so, for large firms, leaving the trade group allows them to keep

up with consumers at their own pace. The weak top-down nature of GMA is causing it to quickly

lose credibility by frustrating the powerful members enough to leave altogether and hire more in-

house lobbyists who will better represent their interests in Washington.20 Mars left GMA to

“more effectively drive…meaningful progress…by working with other like-minded companies

and through other sector-specific trade associations and collaborations.” Coalition building is

still an important resource for companies seeking attention to their goals in Washington.21

Another group that represents the interests of the chocolate industry is the Fine Chocolate

Industry Association (FCIA) which is a non-profit organization that promotes the “artistry and

craftsmanship” of premium chocolate makers. Members include cacao growers and producers,

chocolate makers, chocolatiers, suppliers, pastry chefs, and retailers who believe in and

contribute to the mission of defining industry standards and promoting “quality, innovations,

ethical sourcing, and best practices.”22 FCIA defines its niche as the only group dedicated

completely to the fine chocolate sector of the industry. Members receive the material benefits of

exclusive newsletters and online resources, as well as the solidary benefits of joining a

community of professionals who share an interest in distinguishing fine chocolate from mass

market products to further the rapid growth of the fine chocolate sector.

As John Downs, the CEO of the NCA, expressed in a recent article, the FCIA and NCA

together truly define the importance of the industry, and “collaboration ensures [the] chocolate

category’s future.” Chocolate isn’t an average product; it can improve emotional well-being and

helps make memories.23 The common goal for the chocolate industry is to help consumers

celebrate the role of chocolate in their lives (and create messages that encourage them to keep
 8

consuming it). Consumers may not experience the benefits of being part of these groups that

represent the interests of the industry, but consumers do frequently experience the benefits of the

existence and growth of the chocolate industry. The interests of corporations, trade groups

representing industry professionals, and consumers should ultimately overlap with this positive

view of how chocolate can make the world a better place.

Group Actions Influencing the Future of Chocolate

Chocolate is considered less of a real food in America than in Europe, as companies

market it as an indulgence, not showing how it could be eaten frequently in a balanced diet.24

Nevertheless, Americans are beginning to eat darker chocolate for its health benefits, allowing a

chocolate revolution to take place, as traditional manufacturers release low calorie, low fat, and

low sugar chocolates, as well as dark chocolate alternatives to their established milk chocolate

favorites.25 Many studies have reported that chocolate can reduce the risk of cardiovascular

disease and cancer and can positively influence mood; however, these benefits are associated

with high cocoa content, less processed chocolate.26 They apply more directly to dark chocolate

defined as “fine” by the FCIA, which includes nothing more than “cacao liquor, sugar, cocoa

butter, lecithin, and vanilla,” rather than to the endless candy bar varieties made by Mars and

Hershey that many Americans consume.27

According to Marion Nestle, corporations directly influence the dietary advice available

to consumers by allying with nutrition experts and funding research that will help them sell their

products.28 The corporations themselves are not traditional membership organizations, as no one

has to pay to access the information they publish online, but it is likely that anyone interested in

such information is a paying customer; their constituency is thus loyal consumers becoming

more loyal with the suggestion that consumption of the companies’ products is beneficial to their
 9

health. Consumers who respect and revere the power of these companies have no reason to

neglect the scientific analyses they provide, although the sponsored research may only serve the

interests of the industry, especially when it is used as an advertisement.29 Nestle described the

downside of industry-sponsored research in an interview in 2013:

Sponsorship perverts science. Sponsored research is not about seeking truth or

adding to public knowledge. It is about obtaining evidence to defend or sell
the sponsor’s product, to undermine research that might suggest that a product
is unhealthy, to head off regulation, and to allow the product to be marketed
with health claims.30

Nevertheless, manufacturers provide research that contributes to the healthy chocolate

message, leading consumers to believe that their favorite candy bars (at least the dark chocolate

ones) are healthy, despite the high sugar content that dramatically reduces the quality and

effectiveness of the cacao. Hershey sponsored a study at Northern Arizona University in 2015,

using Hershey’s chocolate as samples, that concluded that eating dark chocolate increases brain

activity to help maintain attention. Researchers at the Hershey Center for Health and Nutrition

supported the project, so the integrity of the study could be questioned, with the desired outcome

of increasing sales. With such studies, the marketing of chocolate as an indulgent treat has

somewhat transitioned to messaging that chocolate is a health food, although Mars has recently

released a statement saying that “chocolate is a treat and should be enjoyed as such, and in

moderation.”31 Mars, along with many institutions around the world, has researched cocoa

flavanols and their health effects for over 20 years, and the Mars Center for Cocoa Health

Science was established in 2012 to provide access to data regarding the cardiovascular benefits

of cocoa flavanols. Mars has also experimented with how to preserve the flavanols in the

chocolate production process, as they are lost in traditional manufacturing.32 Chocolate lovers
 10

want to believe this research, as they may look for justification to eat chocolate, but it can lead to

significant public confusion. Consumers are likely to buy more chocolate because of these tactics

used by corporations, but the transparency that the government should hold companies

accountable to is somewhat lost. While “fine” dark chocolate that is not very processed and

contains little sugar may have desirable health benefits, those benefits are being applied to all

dark chocolate. These major investments in scientific efforts may steer the country’s scientific

agenda away from what the public or the government would prefer to use resources for,

advantaging the corporations who direct the public conversation.33

Corporations may also participate in elections to build relationships with potential

lawmakers who can give them access to the policymaking process after the election.34 Very few

companies have engaged in independent spending in the post-Citizens United environment in

order to maintain a nonpartisan presence, but they use connected PACs to support candidates

who can affect their businesses.35 While both Mars and Hershey do not use company funds for

political donations or electioneering communications, Hershey does have its own PAC that

contributes to federal candidates.36 The Hershey Company PAC raised $67.5 thousand in the

2018 cycle and spent $69.9 thousand, with a high of $3,000 donated to Pennsylvania Senator Pat

Toomey. Because Hershey is headquartered in Pennsylvania and has half of its manufacturing

plants located there, the company is a major constituent of Senator Toomey. Donations maintain

the relationship and the lobbying resource, especially as Senator Toomey currently occupies the

Senate candy desk.37 Similarly, in 2016, the PAC for Mondelēz International greatly supported

Representative Bob Dold because he represents the district of the company’s global

headquarters. The NCA contributed $208,516 to federal elections in 2016, supporting more

Republicans than Democrats, as Republicans are traditionally more supportive of corporate

 11

interests and the independence of business.38 Election spending allows organizations to build the

relationships necessary for future lobbying, essentially “buy[ing] corporate influence over

government decisions.”39

While companies do not typically use resources to support candidates or parties, they

often spend to advocate for issues or legislation. Election contributions provide access to

politicians, but the “revolving door” phenomenon also creates strong relationships (and conflicts

of interest) between lobbyists and government officials, as they exchange jobs in government

and the industry. According to the Center for Responsive Politics, 12 of the 16 lobbyists that

Mars employs, in-house and via Squire Patton Boggs, are former government employees.40 The

revolving door gives lobbyists access to and knowledge of the policy process that they can use to

their advantage, often favoring the industry.41 Members of corporations and interest groups can

also serve on agency advisory committees; the Mars Global Director of Scientific Affairs served

on the FDA Science Board before she moved on to the USDA.42 Mars has developed great

influence over the government through traditional interest group lobbying tactics. Similarly,

Nestlé has developed a strong lobbying strategy to influence policy and protect the company’s

interests. Nestlé spent $1.31 million on lobbying in 2016 (down from $4.8 million in 2013),

$1.21 million of which was spent directly by in-house lobbyists.43 Nestlé has since hired more

in-house lobbyists after leaving the GMA to ensure that the company retains its strong reputation

and representation.44 Additionally, the connection to the NCA and other trade groups gives large

chocolate manufacturers a great power advantage in affecting legislation and could ultimately

determine the future of chocolate regulations.

While Mars can lobby individually on labeling, marketing, and the “regulatory

development of health and nutrition claims,” the NCA has much more power in combining the
 12

influence of hundreds of industry professionals.45 The NCA has engaged in unique lobbying of

the Trump administration by hosting multiple events at Trump hotels, and it planned to spend $2

million on lobbying in 2017 to improve relationships with members of Congress, “the

administration, and regulatory agencies.”46 A Republican president offers the opportunity to

deregulate the industry; however, as discussed earlier, the NCA cannot support issues that would

divide or isolate its members. Before the Chocolate Manufacturer’s Association became part of

the NCA, the 2007 cocoa butter versus vegetable oil debate created conflict between large

manufacturers and small makers. Large manufacturers wanted to be able to use vegetable oil to

cut costs without hurting their reputations, as the dark, premium chocolate trend was beginning.

This trend has continued, and any regulation on what can be labeled as dark chocolate would

similarly put large and small producers at odds. The FCIA believes in “transparent labeling and

marketing practices,” but this goal is not in line with the traditional practices of larger

businesses.47 Fine chocolate makers tout their high cocoa content, organic, fair-trade, and single

origin labels to distinguish themselves, and might desire dark chocolate regulations to gain an

advantage in the market. With regards to fine, dark chocolate, the NCA is an inadequate trade

organization, allowing for even greater interest group advantage for wealthy corporations. It fails

to ally the chocolate industry, and the small companies’ interests on the dark chocolate issue are

neglected because they lack a presence in the lobbying community independent from the NCA.

Conclusion

Controversy has struck the food industry as companies and groups grapple with changing

consumer tastes. Helena Bottemiller Evich and Catherine Boudreau blame the “splintering of the

food lobby” on moms’ and millenials’ desires for healthier and more transparent options. Iconic

brands are already struggling as consumers develop tastes for healthy, organic, high-quality
 13

products; according to a Credit Suisse analysis, the “top 20 U.S. food and beverage companies

lost $18 billion in market share between 2011 and 2017.”48 Large firms still face a conflict

between fulfilling consumer demands and protecting themselves from regulations that could hurt

their businesses; however, companies are learning to adopt more progressive marketing

strategies to appeal to the younger generation. Large companies sponsor research favorable to

their products and constantly gain influence within the federal government with which the small

companies cannot compete. Recent commitments to become more sustainable and make their

chocolate products somewhat more traceable may be the extent that the manufacturers are

willing to change for their customers.

As of July 2018, Mars and Nestlé are formalizing a successful interest alliance of the past

by helping to launch a new group, The Sustainable Food Policy Alliance, to fight for progressive

food policy and lobby on product transparency and nutrition.49 It is already accelerating the

efforts for consumer-friendly packaging by combining the power that these companies have in

Congress and the FDA. The consumption choices of customers show their yearning for change,

and the companies and trade groups representing the industry are beginning to be held

accountable to these new demands.

If consumers’ demands continue to evolve, and manufacturers become even more willing

to respond to those demands, the chocolate industry may eventually be able to establish a

common understanding of the health benefits of chocolate and how those benefits can be applied

to the marketing of dark chocolate products. Such an agreement could accelerate steps towards

an FDA-approved standard of identity for dark chocolate that would maximize the transparency

of the chocolate industry. The development of a new regulation will depend on a shift in the

lobbying efforts of large manufacturers, who will likely not reverse their philosophy that the
 14

government should refrain from regulating business. Nevertheless, chocolate producers driven by

profits and chocolate consumers driven by a simple love for chocolate will work together to

maintain the strength of the industry to ensure that chocolate will remain abundant and delicious.

NOTES
1
Rodney Snyder, "History of Chocolate: Chocolate in the American Colonies," Colonial
Williamsburg: That the Future May Learn from the Past, , accessed December 07, 2018,
http://www.history.org/history/teaching/enewsletter/volume9/jan11/featurearticle.cfm.
2
Carla D. Martin, "Chocolate 101" (Lecture, New England Chocolate Festival, MA, Boston,
October 13, 2018).
3
Ibid.
4
"North America Chocolate Market Size Analysis Report By Product (Dark, Milk, White), By
Application (Everyday, Premium, Gourmet, Seasonal), By Country, And Segment Forecasts,
2018 - 2025," Grandview Research, January 2018, accessed December 07, 2018,
https://www.grandviewresearch.com/industry-analysis/north-america-chocolate-market.
5
"Chocolate Industry Analysis 2018 - Cost & Trends," Franchise Help, accessed December 04,
2018, https://www.franchisehelp.com/industry-reports/chocolate-industry-analysis-2018-cost-
trends/.
6
“Chocolate, as Defined by FDA,” Registrar Corp, October 28, 2015, accessed November 18,
2018, https://www.registrarcorp.com/fda-chocolate-standard-identity/.
7
Ibid.
8
Times-Dispatch Staff, "Practical Nutrition: A Bit of Dark Chocolate Is a Good Thing, but Go
for 70 Percent Cacao: Cocoa Meringue Kisses," Richmond Times-Dispatch, February 08, 2012,
accessed December 07, 2018, https://www.richmond.com/holiday/valentines-day/practical-
nutrition-a-bit-of-dark-chocolate-is-a-good/article_ce2a8bb4-a92e-5c6a-aaa6-
6436a16592be.html.
9
Martin.
10
"U.S. Market Share of Chocolate Companies, 2017," Statista, accessed December 09, 2018,
https://www.statista.com/statistics/238794/market-share-of-the-leading-chocolate-companies-in-
the-us/.
11
Mara P. Squicciarini and Johan Swinnen, The Economics of Chocolate (New York, NY:
Oxford University Press, 2016), 125.
12
GO 210 Class Notes 10/3/18.
13
Squicciarini and Swinnen, 128.
14
GO 210 Class Notes 10/3/18.
15
"Who We Are," NCA, accessed December 09, 2018, https://www.candyusa.com/who-we-are/.
 15

16
"NCA Members," NCA, accessed December 09, 2018, https://www.candyusa.com/nca-
members/?ctype=SUPP; "Bixby & Co.," Bixby & Co., accessed December 04, 2018,
https://bixbyco.com/.
17
GO 210 Class Notes 10/3/18.
18
“Advocacy,” NCA, accessed December 09, 2018, https://www.candyusa.com/advocacy/.
19
"GMA," GMA, accessed December 09, 2018, https://www.gmaonline.org/.
20
Chase Purdy, "The Death of the ‘Big Food’ Era Is Imminent after the Industry's Biggest
Lobbying Group Crumbles," Quartz, March 05, 2018, accessed December 09, 2018,
https://qz.com/1219503/food-manufacturers-are-leaving-the-grocery-manufacturers-association-
signaling-an-end-of-the-big-food-era/.
21
Douglas Yu, "Hershey Drops out of Grocery Manufacturers Association after Mars and Nestlé,"
Confectionerynews.com, January 08, 2018, accessed December 09, 2018,
https://www.confectionerynews.com/Article/2018/01/08/Hershey-exits-Grocery-Manufacturers-
Association-after-Mars-and-Nestle.
22
"About Us," Fine Chocolate Industry Association - About FCIA, accessed December 09, 2018,
https://www.finechocolateindustry.org/about.
23
John Downs, "Collaboration Ensures Chocolate Category's Future," NCA, December 7, 2018, ,
accessed December 09, 2018, https://www.candyusa.com/news/collaboration-ensures-chocolate-
categorys-future/.
24
Squicciarini and Swinnen, 121.
25
Squicciarini and Swinnen, 122.
26
Squicciarini and Swinnen, 137; 147.
27
"Fine Chocolate," Fine Chocolate Industry Association - About FCIA, accessed December 10,
2018, https://www.finechocolateindustry.org/fine-chocolate; Squicciarini and Swinnen, 150.
28
Marion Nestle, Food Politics: How the Food Industry Influences Nutrition and Health,
(Berkeley and Los Angeles, CA; London: University of California Press, 2002), 93.
29
Ibid, 119.
30
Annie Wu, "Hershey's Just Paid for a Study to Convince You Chocolate Is Healthy," The
Epoch Times, October 09, 2015, accessed December 10, 2018,
https://www.theepochtimes.com/hersheys-just-paid-for-a-study-to-convince-you-chocolate-is-
healthy_1355288.html.
31
Oliver Nieburg, "Mars: We Have No Agenda to Create Chocolate Health Halo with Cocoa
Flavanol Studies," Confectionerynews.com, January 17, 2018, accessed December 10, 2018,
https://www.confectionerynews.com/Article/2018/01/17/Mars-defends-flavanol-research-
Chocolate-should-not-be-considered-a-health-food.
 16

32
"Legacy of Research," Mars Center for Cocoa Health Science, accessed December 10, 2018,
https://www.marscocoascience.com/research.
33
GO 210 Class Notes, 9/24/18.
34
GO 210 Class Notes, 10/17/18.
35
GO 210 Class Notes, 10/24/18.
36
"Our Public Policy and Advocacy," Mars, Incorporated, accessed December 10, 2018,
https://www.mars.com/global/about-us/policies-and-practices/public-policy-advocacy;
"Advocacy Expenditures Report," Hershey, accessed December 10, 2018,
https://www.thehersheycompany.com/en_us/investors/shareholder-information/advocacy-
expenditures-report.html.
37
Unless otherwise noted, the campaign finance and lobbying data presented herein is based on
the information available from the Center for Responsive Politics, www.opensecrets.org
38
Oliver Nieburg, "How Candy Lobbying Dollars Were Spent in Election Year,"
Confectionerynews.com, November 10, 2016, accessed December 10, 2018,
https://www.confectionerynews.com/Article/2016/11/10/How-candy-lobbying-dollars-were-
spent-in-election-year.
39
Nestle, 107.
40
"Mars Inc: Summary," OpenSecrets.org, accessed December 10, 2018,
https://www.opensecrets.org/orgs/summary.php?id=D000042123.
41
GO 210 Class Notes 10/29/18.
42
"Former USDA Undersecretary to Join Iowa State University Food Science and Human
Nutrition Faculty," Iowa State University College of Agriculture and Life Sciences, July 17,
2017, accessed December 10, 2018, https://www.cals.iastate.edu/news/releases/former-usda-
undersecretary-join-iowa-state-university-food-science-and-human-nutrition.
43
Kit O'Connell, "Nestle Spent $11M Lobbying Congress to Control Water, Cocoa & Trade
Since 2013," MintPress News, September 29, 2016, accessed December 10, 2018,
https://www.mintpressnews.com/nestle-spent-11m-lobbying-congress-to-control-water-cocoa-
trade-since-2013/220853/.
44
Purdy.
45
"Our Public Policy and Advocacy;” GO 210 Class Notes 10/3/18.
46
Clint Rainey, “Oh Great, So Now We Have to Protest Candy?” Grub Street, March 8, 2017,
accessed November 18, 2018, http://www.grubstreet.com/2017/03/candy-industry-lobby-
spending-lots-at-trump-hotels.html.
47
"About Us," Fine Chocolate Industry Association - About FCIA
48
Helena Bottemiller Evich and Catherine Boudreau, "The Big Washington Food Fight,"
POLITICO, November 26, 2017, accessed December 10, 2018,
https://www.politico.com/story/2017/11/26/food-lobby-consumer-tastes-washington-190528.
49
Caitlin Dewey, "Four of the World's Largest Food Companies Have a New Plan for Fixing
Food and Farm Policy," The Washington Post, July 12, 2018, accessed December 10, 2018,
 17

https://www.washingtonpost.com/news/wonk/wp/2018/07/12/four-of-the-worlds-largest-food-
companies-have-a-new-plan-for-fixing-food-and-farm-policy/?utm_term=.ac23b9118f1e.