Can I Make Chocolate Without Cocoa?

Milk chocolate and dark chocolate both contain cocoa solids as an essential ingredient.
Cocoa butter, sugar, vanilla, lecithin and whole milk powder are added to the cocoa solid to make milk chocolate.
Cocoa butter, sugar and lecithin are added to the cocoa solids to make plain or dark chocolate.

However, white chocolate does not require cocoa solid at all. You simply require cocoa butter, sugar, lecithin, vanilla and whole milk powder to make white chocolate.

As cocoa solids are considered to be an essential ingredient in chocolate-making, 'white chocolate' is not actually considered to be a type of chocolate in many countries. Prior to 2004, the US needed a special temporary marketing permit, in order to call a product without cocoa-solids a 'chocolate'.
However since 2004, both the US and the EU have adopted a policy whereby white chocolate can be called as such, so long as it contains no less than 20% cocoa butter and 14% milk solids.