I disagree, as do Tunnock's themselves who describe it as a wafer.
Tunnocks's use the Scottish definition… if it can be deep fat fried it is a chocolate bar, it it can't it is a biscuit. If you fried one of these it would ignite.
my vote goes for the humble Tunnocks Caramel Waffer, the bog standard one not the log that is covered in coconut. (although i'm biased as I'm a local boy)
It is the best biccy by far (my defination is if it gets dunked in tea or coffee its a biccy)
Rather partial to a Twix – now is this a biscuit or a chocolate bar?
That's actually a question of great interest to the taxman, as VAT is payable on biscuits but not cakes. McVities spent a lot of time and money proving that Jaffa Cakes were actually cakes for this reason: http://blogs.warwick.ac.uk/hollycruise/entry/jaffa_cakes_and/
As far as im aware though a Twix is the only chocolate bar with a solid biscuit base through its entire length – others only have biscuit pieces or areas of crunch or alternative texture.
Now – compare this with a 'rocky' say for example – I think most would comment that this is a biscuit – they both have very similar attributes – but one is clearly marketed as a biscuit and the other a chocolate bar.
I would ask my mate from Suffolk Trading Standards but I'm still scarred from his explanation on the EC position on whether quiches are flans or vice / versa.