Yes, according to US CBP officers, you should declare it as food. I bring chocolate every time I fly from Europe. Generally what happens next is they ask what exactly you are bringing, you say "chocolate" and they let you go.

When traveling internationally, the requirement to declare chocolate depends on the specific customs laws of the country you are entering. In the United States, Customs and Border Protection (CBP) mandates that you declare all food items, including chocolate; however, solid, commercially packaged chocolate is generally permitted for personal use and rarely incurs duty. In Australia, you do not need to declare chocolate if it is commercially prepared, packaged, and weighs less than 10kg, provided it does not contain prohibited ingredients like meat (e.g., bacon bits). The UK and Canada follow similar guidelines: as long as the chocolate is in its original retail packaging and intended for personal consumption, it is typically allowed without issue. The key is to always be honest on your declaration form; failing to mention food can result in fines and delays, even for "safe" items like a box of truffles. When in doubt, it is safer to check the "Yes" box for food and simply let the officer see that it is just a candy bar.