The cocoa industry promised to end child labor by 2005. Then 2010. Then 2020. The deadline is now 2030. Meanwhile, "mass balance" certifications let companies buy credits rather than trace beans. One brand has been building an actual alternative since 2005.
| Brand | Ownership | Cocoa Sourcing | Ingredients | Certifications | Labeling | Labor Record | Price | Zone |
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Tony's Chocolonely
Dark, Milk, White Chocolate
Independent — Verlinvest, Jam Jar investors; Mission Lock 2023
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Mission-Locked | 100% traceable Bean-to-bar, farm-level | ✓ Simple, disclosed |
✓ B Corp · Fairtrade |
✓ No misleading claims |
✓ 10.5% vs 46.7% avg |
~$5–6 per 180–240g bar | High Transparency |
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Formula
Cocoa mass, cocoa butter, sugar, whole milk powder (milk chocolate variants). Short, clean ingredient lists. No lecithin (unlike most chocolate which uses soy or sunflower lecithin as emulsifier). Dark chocolate: just 3 ingredients.
Owner
Independent — investors include Verlinvest and Jam Jar. In June 2023, Tony's created the Mission Lock: an independent legal structure with a golden share that can prevent any changes to the company's mission, five sourcing principles, or senior leadership obligations — regardless of future shareholder changes. The first structure of its kind in the industry.
Key Strengths
✓ 100% bean-to-bar traceable cocoa, farm-level
✓ CLMRS active in supply chain — publishes exact child labor rates ✓ Pays above Fairtrade price + 5-year minimum contracts with farmers ✓ B Corp score 125/100 (median company: 50.9) ○ Revenue ~€150M — still a fraction of Hershey/Nestlé scale Key Finding
Tony's is the category benchmark for the same reason DripDrop is the electrolyte benchmark: it built a transparent supply chain infrastructure instead of buying credentials. The Mission Lock is structurally unprecedented — it makes the mission legally irrevocable regardless of who owns the company in the future. This is what supply chain accountability looks like.
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Hu
"Get Back to Human" Chocolate
Mondelēz International — acquired January 2021 (~$340M)
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Mondelēz | Fairtrade (mass balance) Organic + Fair Trade certified | ✓ 3 ingredients, Ultrasimple™ |
✓ USDA Organic · Fairtrade |
✓ Honest label |
~ Mondelēz Cocoa Life |
~$4–5 per 2.1oz bar | Yellow |
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Formula
Organic cacao, unrefined coconut sugar, organic cocoa butter. Three ingredients. No lecithin, no refined sugar, no palm oil, no emulsifiers. No PGPR (compare to Hershey's classic bars). "Ultrasimple™" guardrails have remained intact post-Mondelēz acquisition through 2025.
Owner
Mondelēz International (NASDAQ: MDLZ) — maker of Oreo, Cadbury, Toblerone, Ritz. Took minority stake 2019 via SnackFutures venture hub. Full acquisition closed Jan 4, 2021 at ~$340M. This is the same company whose Cocoa Life program covers only ~45% of its cocoa. Hu operates as a separate business within Mondelēz North America Ventures.
Watch Conditions
✓ Formula held clean post-acquisition (2021–2025)
✓ USDA Organic, Fairtrade — certifications real ✗ Mondelēz owns Oreo, Cadbury — conflict of interest is structural ✗ Mondelēz Cocoa Life covers only ~45% of their total cocoa ○ Fairtrade certification is mass balance, not traceable to specific farms Key Finding
Hu's ingredient story is genuinely excellent — 3 ingredients, organic, no emulsifiers, no refined sugar. The conflict is structural: Mondelēz acquired a premium clean-label brand while continuing to operate Cadbury and Oreo with entirely different sourcing standards. The formula integrity watch condition is real: Mondelēz has incentive to quietly reduce coconut sugar and add lecithin as cocoa prices rise.
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Lily's
"Stevia Sweetened" Chocolate
The Hershey Company — acquired June 2021 ($425M)
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Hershey | Fair Trade USA Certified, not traceable | ~ Short list, erythritol |
~ Fair Trade · Non-GMO |
✗ Active class action |
✗ Hershey supply chain |
~$4–5 per 2.8–3oz bar | Red |
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The Lawsuit
Active class action (2024): Loza, Hall & Rivera v. The Hershey Company. Front labels read "Stevia Sweetened" and "No Sugar Added." Complaint alleges the primary, predominant sweetener is actually erythritol — a sugar alcohol — not stevia. Stevia appears near the end of the ingredient list. Erythritol appears second, by weight. Consumers paid a price premium believing they were getting a stevia-sweetened product.
Ingredients
Unsweetened chocolate, erythritol, inulin, stevia extract, sunflower lecithin, vanilla. Erythritol is listed before stevia — meaning it's present in higher quantity. Erythritol is a fermented sugar alcohol (typically from corn); stevia is a plant extract. Erythritol has been linked in 2023 Cleveland Clinic research to elevated cardiovascular risk markers at the doses found in processed foods.
Watch Conditions
✗ "Stevia Sweetened" front label when primary sweetener is erythritol by weight
✗ Active class action — consumer harm claim, not just technical labeling dispute ✗ Owned by Hershey — same company reformulating Reese's (Brad Reese controversy, Feb 2026) ○ Fair Trade USA certified — real but not fully traceable ✓ Short ingredient list; no artificial colors; original formula from 2012 founder still intact Key Finding
Lily's is the Reese's story on a smaller scale: a health-halo brand acquired by Hershey, with label claims that appear to misrepresent the primary sweetener to consumers willing to pay a premium for stevia. The "Stevia Sweetened" claim is front-of-pack, prominent, and — according to the active lawsuit — factually misleading. Same ownership pattern, same transparency gap.
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Hershey's
Milk Chocolate / Special Dark
The Hershey Company (Hershey Trust voting control) · $11.7B revenue
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Hershey Trust | ~80% "certified" Mass balance, not traceable | ✗ PGPR, TBHQ added |
✗ No B Corp, no NSF |
✗ Compound coating issue |
✗ 2001 pledges unmet |
~$2–3 per 1.55oz bar | Red |
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Formula Concerns
Classic Milk Chocolate (1.55oz): Sugar, Milk, Chocolate, Cocoa Butter, Milkfat, Lecithin (Soy), PGPR, Vanillin. PGPR (polyglycerol polyricinoleate) is a castor oil emulsifier added to replace cocoa butter — reduces cost. TBHQ (tert-butylhydroquinone) is a synthetic preservative. Both absent from H.B. Reese's original 1928 formula. CFO confirmed "recipe adjustments" to investors during 2024 cocoa price crisis. Brad Reese went public Feb 2026 alleging compound coating substitution in line extensions.
Ownership
Hershey Trust Company holds majority voting power — a philanthropic trust funding Milton Hershey School. Unusual structure: blocks market accountability (blocked Mondelēz $23B acquisition in 2016) but also blocks conventional shareholder pressure. Gross margins collapsed from 47.3% to 33.5% in 2024 due to cocoa price spike. Now explicitly treating reformulation as a margin-recovery strategy.
Key Gaps
✗ PGPR reduces cocoa butter requirement — cost optimization in formula since 2006
✗ TBHQ synthetic preservative, banned at Whole Foods ✗ "Milk chocolate" vs "chocolate candy" split across Reese's line — legal but deceptive ✗ 2001 child labor pledges broken through 4 deadline extensions ✗ ~80% "certified" cocoa = mass balance credits, not traceable supply chain Key Finding
Hershey is navigating a margin crisis and a legacy formula crisis simultaneously — and handling both poorly from a transparency perspective. Reformulation is being communicated to investors and concealed from consumers. Child labor commitments have been extended four times in 24 years. The gap between what Hershey tells Wall Street and what it tells Main Street is the product. See full Reese's/Hershey Deep Trace for complete analysis.
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Nestlé
KitKat, Toll House, Crunch, Butterfinger
Nestlé S.A. (SIX: NESN) — CHF 92B revenue (2024) · largest food company by revenue
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Mega-Corp | Rainforest Alliance Mass balance, not traceable | ✗ Additive-heavy |
✗ Rainforest Alliance (mass balance) |
~ Cocoa Plan disclosed |
✗ Pledges broken since 2001 |
~$1–2 per standard bar | Red |
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The Pledge Record
2001: Nestlé, Hershey, Mars and other companies signed the Harkin-Engel Protocol — a voluntary pledge to eliminate child labor in West African cocoa by 2005. It was not met. 2008: Extended to 2010. Not met. 2010: Reduced ambition + extended to 2020. Not met. 2018: Extended to 2025. Appears unlikely to be met. Current pledge: 2030. An estimated 1.56 million children still working in West African cocoa fields as of 2022.
The "Mass Balance" Problem
Rainforest Alliance "mass balance" certification allows Nestlé to claim its chocolate uses certified cocoa while the actual beans in a given product may not be certified. The company purchases a volume of certified cocoa equivalent to what it uses — but the beans are fungible in the supply chain. Nestlé Cocoa Plan covers 298,000+ tons and 180,000+ farmers, but supply chain traceability to the farm level is not yet universal.
Key Gaps
✗ 24 years of broken child labor pledges
✗ Rainforest Alliance mass balance ≠ traceable cocoa ✗ 1.56M children still in cocoa supply chains industry-wide ✗ Dropped "chocolate" labeling from UK products (Toffee Crisp, Blue Riband) Dec 2025 after reformulation below minimum cocoa threshold ○ Nestlé Cocoa Plan is the most transparent of the Big Three — at least they publish data Key Finding
Nestlé is the most documented example of the industry's structural failure: large-scale investment in supply chain improvement programs that do not keep pace with the scale of the problem. The Cocoa Plan is real and better than nothing. The gap between Nestlé's narrative ("we're committed to change") and the documented reality (1.56M children still in supply chains, 24 years of broken pledges) is the finding. Mass balance certification is the industry's mechanism for claiming accountability without delivering traceability.
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Founded 2005 by Dutch journalists who discovered chocolate companies buying cocoa from child-labor farms. Built a 100% traceable supply chain from scratch — farm-level CLMRS monitoring, five-year farmer contracts, above-Fairtrade pricing. Child labor rate in their supply chain: 10.5%, versus a 46.7% industry average. In 2023, created the Mission Lock: a legally irrevocable governance structure that protects the mission regardless of future ownership. The first of its kind in the industry.
Mixed Transparency — Acquisition WatchThe cleanest ingredient story in mainstream premium chocolate: three ingredients, organic cacao, unrefined coconut sugar, organic cocoa butter — no lecithin, no palm oil, no refined sugar. Bootstrapped for nine years before taking any outside money. Formula has held clean post-Mondelēz acquisition (2021–2025). But Mondelēz also makes Oreo, Cadbury, and Toblerone — and its own Cocoa Life program covers only ~45% of its total cocoa. The conflict of interest is structural. Watch the formula.
Low Transparency — Active Labeling LawsuitFounded 2012 by Cynthia Tice as a genuinely sugar-free alternative for diabetics and keto eaters. Acquired by Hershey for $425M in 2021. An active 2024 class action alleges that despite the "Stevia Sweetened" front-of-pack claim, the primary sweetener by weight is erythritol — a corn-fermented sugar alcohol with no stevia health halo. Erythritol appears second in the ingredient list; stevia appears near the end. Consumers paying a premium for stevia may be getting something fundamentally different.
Low Transparency — Reformulation + Labor GapPGPR (castor oil emulsifier replacing cocoa butter) added in 2006 — 18 years before the cocoa price crisis. TBHQ (synthetic preservative, banned at Whole Foods) in the formula. CFO confirmed "recipe adjustments" to investors in 2024; consumers got no disclosure. Brad Reese (grandson of H.B. Reese) publicly accused the company in February 2026 of replacing milk chocolate with compound coating across Reese's line extensions. Hershey Trust governance structure insulates the company from conventional market accountability. Four child labor pledge extensions since 2001.
Low Transparency — 24 Years of Broken PledgesThe largest food company by revenue. The Nestlé Cocoa Plan is the industry's most documented supply chain improvement effort — and it still hasn't solved the problem. An estimated 1.56 million children remain in West African cocoa supply chains. Rainforest Alliance "mass balance" certification means Nestlé buys equivalent volumes of certified cocoa, not that the beans in a given bar are certified. In December 2025, Nestlé dropped "chocolate" labeling from UK products including Toffee Crisp after reformulation reduced cocoa content below the legal 20% minimum.
The chocolate category has a transparency problem that is older, more documented, and more structural than any supplement category Traced has reviewed. Hershey, Nestlé, and Mars jointly signed the Harkin-Engel Protocol in 2001 — a voluntary pledge to eliminate the worst forms of child labor in West African cocoa by 2005. That deadline passed. It was extended to 2010. Then 2020. Now 2025. Now 2030. An estimated 1.56 million children remain in cocoa-growing supply chains. The industry has spent 24 years extending promises instead of meeting them.
The mechanism that allows this to continue is "mass balance" certification. Rainforest Alliance and Fair Trade allow companies to purchase a volume of certified cocoa equivalent to what they use, without requiring that the actual beans in a given product come from certified farms. This is legally compliant. It is not what most consumers understand when they see a Rainforest Alliance leaf on a chocolate bar. Tony's Chocolonely has been making this distinction loudly since 2005 — and publishing the receipts.
The ingredients story runs parallel. PGPR was added to Hershey's formulas in 2006 — 18 years before the cocoa crisis that would make cost-reduction rational — as routine margin management. The same castor oil emulsifier that reduces cocoa butter requirement is in the bar you buy today. The same bar that costs twice what it did before the cocoa price spike. Reformulation as a strategy predates every external justification being offered for it now.
Hu represents the most interesting case in the category: a brand that built its entire identity around ingredient simplicity, held independent for nine years specifically to protect that identity, and then sold to Mondelēz — the maker of Oreo and Cadbury — for $340M. The formula has held clean through 2025. The structural conflict has not resolved. Watching what happens to Hu's ingredients over the next five years may be the most legible real-time test of whether conglomerate acquisition destroys clean-label brands.