White chocolate is a confectionery made of sugar, milk, and cocoa butter, but no cocoa solids. According to the American FDA, to legally be marketed as "white chocolate," a product must contain at least 20% cocoa fat, at least 3.5% milk fat, and at least 14% total milk solids. It also cant consist of more than 55% nutritive carbohydrate sweetener. In translation, a theoretical American white chocolate bar could legally contain 55% sugar, 20% cocoa butter, 17.5% milk powder, and 7.5% something else, usually a combination of fillers such as lecithin, flavorings, whey products, and more powdered milk. Most white chocolate contains only the legal minimum of 20% cocoa butter, meaning that the rest of the mass is made up of sugar and high-fat milk powder. White chocolate does not contain cocoa solids, the primary non-fat constituent of conventional chocolate liquor. Instead, the main ingredient in white chocolate is cocoa butter, which gives it a distinct creaminess.