jlh, these are technically not on plan because they include such a high amount of saturated fat. Furthermore, they include a lot of unpronounceable ingredients, which goes against the general tenor of this WOE (Way of Eating)--we try to avoid processed foods.
That said, you technically can have these in Phase 1, though you have to limit your calories from "sweet treats" (best described as non-nutritive sweets that are sweetened with sugar alcohols) to 75-100 calories per day, both because too much of them causes terrible side effects and because they can cause cravings. In addition, many sugar-free chocolates are made with malitol. Some of us (me included) have found that malitol, in particular, causes cravings. So I'd avoid it in Phase 1 until you know how it affects you.
An option for sugar-free chocolate that doesn't have as many odd ingredients and has no sugar alcohols is
CarbSmart (used to be Eat Well, Be Well). You can get chocolate chips, though I don't know if they still make chocolate bars.
In the meantime, some options are: NSA Fudgesicles,
Kara's Fabulous Beany Brownies!,
Chocolate Breeze Cups (with the SF choc. syrup, these would have a ton of unpronounceable ingredients, but if you go with the option in brackets, they're fine),
Chocolate Milkshake,
Warm Chocolate Cakes with Coffee Creme Anglaise,
Chocolate Meringue Kisses,
Chocolate Shake, or
Decadent Fudge Brownies.
For more ideas, check out the
Desserts - Phase 1 recipe forum!