Private label chocolate manufacturers make bars, truffles and gift chocolates and wrap them under your brand. US makers publish minimums from a $250 order or 100 bars up to 500 pieces per design and flavor. Chocolate has three rules most new brands don’t expect: federal recipes decide what you can call “milk chocolate” or “white chocolate”, a Prop 65 settlement sets lead and cadmium warning levels for chocolate sold in California, and Amazon only accepts meltable inventory into FBA during the cooler months.
I’ll compare makers, then cover the standards, heavy metals, labeling, and Amazon’s meltable window.
Chocolate manufacturers and minimums
From each company’s own site, checked in October 2026:
| Manufacturer | Location | Published minimum | Notes |
|---|---|---|---|
| Animas Chocolate Company | Durango, Colorado | $250 minimum order | Private label chocolate |
| Li-Lac Chocolates | New York City | 100 bars, including a one-time mold setup charge | Custom-wrapper bars, closer to corporate gifting |
| Private Label Chocolate | Bluffdale, Utah | 500 pieces per design and flavor | Full private label |
My take: start with a small run of two or three bars from a low-minimum maker, sell them through Q4 gifting, and only commit to 500 pieces per flavor once you know which flavors reorder.
What legally counts as milk, dark or white chocolate
FDA standards of identity (21 CFR Part 163) set minimums:
| Name | Key requirements |
|---|---|
| Milk chocolate | At least 10% chocolate liquor, 3.39% milkfat and 12% total milk solids |
| Sweet chocolate | At least 15% chocolate liquor, less than 12% total milk solids |
| White chocolate | At least 20% cacao fat, 14% total milk solids, 3.5% milkfat; no more than 55% sweetener |
If your product doesn’t meet the standard, it can’t use the name; that’s why some products say “chocolatey” or “made with chocolate”. In my view, ask the maker for the formula percentages that support each name on your label, in writing.
Lead, cadmium and Prop 65
Cacao can carry lead and cadmium. In California, a 2018 Prop 65 consent judgment (As You Sow) set lead and cadmium levels above which a warning is required, scaled by cacao content, with levels that tighten after a later anniversary date:
| Cacao content | Lead (ppm), initial to later | Cadmium (ppm), initial to later |
|---|---|---|
| Up to 65% | 0.100 to 0.065 | 0.400 to 0.320 |
| 65% to 95% | 0.150 to 0.100 | 0.450 to 0.400 |
| Over 95% | 0.225 to 0.200 | 0.960 to 0.800 |
That judgment binds the companies that settled, not every brand, but it’s the clearest benchmark available. I’d ask any maker for heavy metal test results, especially for high-cacao dark bars, and decide on California warnings before you print.
Labeling and allergens
Chocolate is food, so the usual food label rules apply, including allergens. The nine major allergens include milk, soy, tree nuts and peanuts, which show up in many chocolates (soy often as lecithin). Each must be named in the ingredient list, for example “lecithin (soy)”, or in a “Contains” statement. Shared equipment matters too, so ask about allergen controls. Our guide to private label food manufacturers covers the full food label checklist.
Selling chocolate on Amazon: the meltable window
Amazon treats chocolate as meltable inventory. Amazon staff have said FBA accepts meltables from October 16 until April 14 of the following year. Honestly, that makes chocolate a seasonal FBA business; outside the window, plan for FBM with insulated shipping or simply pause.
Also plan for grocery approval if a listing shows “Apply to sell”, and for clear expiration dates. Q4 gifting is the big opportunity, so time production for early October arrival.
For related food categories, see our guides to private label coffee suppliers and private label protein bars. If you’d like a team to source and vet makers, that’s our complete sourcing management service.
FAQ
What is the minimum order for private label chocolate?
Published minimums from US makers include a $250 order, 100 custom-wrapped bars, and 500 pieces per design and flavor for full private label.
What makes chocolate “milk chocolate” legally?
At least 10% chocolate liquor, 3.39% milkfat and 12% total milk solids, under FDA standards of identity.
Does chocolate need a Prop 65 warning?
In California, chocolate above certain lead and cadmium levels may need a warning. A 2018 settlement set levels by cacao percentage that many brands use as a benchmark.
Can I sell chocolate through FBA year-round?
No. Amazon staff have said FBA accepts meltable products such as chocolate from October 16 to April 14.
What allergens are common in chocolate?
Milk, soy (often in lecithin), tree nuts and peanuts. Each must be clearly declared on the label.
What’s the best time to launch a private label chocolate brand?
Before Q4. Gifting season and Amazon’s meltable window line up from mid-October.
Last updated: October 5, 2026. General information, not legal advice. Sources: 21 CFR 163.130; 21 CFR 163.123; 21 CFR 163.124; California AG, As You Sow chocolate consent judgment (PDF); FDA, food allergies; Amazon Seller Forums, meltable inventory; Animas Chocolate Company; Li-Lac Chocolates; Private Label Chocolate.
