It is a matter of definition but this is 100 base Cacao from Bt=rasil and now its a matter of what you do with it.

Chocolate is a product based on cocoa solid and/or cocoa fat. The amount and types of cocoa solids and fat that the term implies is a matter of controversy. Manufacturers have an incentive to use the term for variations that are cheaper to produce, containing less cocoa and cocoa substitutes, although these variations might not taste as good.

There has been disagreement in the EU about the definition of chocolate; this dispute covers several ingredients, including the types of fat used, quantity of cocoa, and so on. But, in 1999, the EU at least resolved the fat issue by allowing up to 5% of chocolate’s content to be one of 5 alternatives to cocoa butter: illipe oil, palm oil, sal, shea butter, kokum gurgi, or mango kernel oil.

A recent workaround by the US confection industry has been to reduce the amount of cocoa butter in candy bars without using vegetable fats by adding polyglycerol polyricinoleate (PGPR), which is an artificial castor oil-derived emulsifier that simulates the mouth-feel of fat. Up to 0.3% PGPR may be added to chocolate for this purpose.

Source: Wikipedia