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.
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Travelers should declare all items being brought from abroad that will remain in the United States. This includes gifts and duty-free purchases. Goods purchased in a duty-free shop are not automatically free of duty upon your return to the United States.
Solid food items (not liquids or gels) can be transported in either your carry-on or checked bags. Liquid or gel food items larger than 3.4 oz are not allowed in carry-on bags and should be placed in your checked bags if possible.
Chocolate (Solid)Solid food items (not liquids or gels) can be transported in either your carry-on or checked bags. Liquid or gel food items larger than 3.4 oz are not allowed in carry-on bags and should be placed in your checked bags if possible.
Fear not, chocoholics! Chocolate bars are absolutely allowed on a plane, whether you're traveling domestically or internationally. The TSA permits solid chocolate bars of any size or quantity to be carried in your carry-on bag. You won't have to bid farewell to your beloved chocolate bars at the security checkpoint.
Yes, you may pack food in your carry-on or checked bag, but remember all food must undergo x-ray screening. Foods that are liquids, gels, or aerosols must comply with the 3-1-1 liquids rule. TSA officers make the final decision on whether certain items are permitted into the secured areas of the airport.
Mailing and Shipping Goods - Customs Duty GuidanceUp to $1,600 in goods will be duty-free under your personal exemption if the merchandise is from an IP. Up to $800 in goods will be duty-free if it is from a CBI or Andean country. Any additional amount, up to $1,000, in goods will be dutiable at a flat rate (3%).