You need a certain amount of cocoa butter to be called milk chocolate. Companies are swapping it out for fats and other simulations.

From the NY Times:

Almost no one noticed when, sometime over the last few years, the packaging on Almond Joy, Mr. Goodbar and Rolo was updated to remove the words “milk chocolate.”

The edits were easy to miss: The description on the front of the Mr. Goodbar wrapper changed from “milk chocolate with peanuts” to “chocolate candy with peanuts.” Almond Joy is now marketed as a “coconut and almond chocolate candy bar.” Rolos are now wrapped in “rich chocolate candy” instead of “milk chocolate.”

...

Experts say high cocoa prices have triggered a wave of “reformulations,” the industry term for recipe changes. As the Halloween season boosts demand, some candy companies are replacing expensive cocoa butter with other fats, a swap that means their products no longer meet the U.S. regulatory definition of milk chocolate and can no longer be called that on packaging.

Also discussed: thinner coatings, chunks of chocolate-like substance instead of real chips, and more sugar to mask the lower quality ingredients.

https://www.nytimes.com/2025/10/30/climate/candy-chocolate-cocoa-prices-climate-change.html