No. This product is not soy free as it lists 2 ingredients that contain soy.

Is Candy Pop, Popcorn M&M's Minis Soy Free?

No. This product is not soy free as it lists 2 ingredients that contain soy.
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Ingredients

Calcium, Potassium, Confectionery Coating (Sugar, Palm Kernel Oil, Nonfat Dry Milk, Cocoa Powder, Soy Lecithin (Emulsifier), Salt), Popcorn, M&M'S® MINIS (Milk Chocolate (Sugar, Chocolate, Skim Milk, Cocoa Butter, Lactose, Milkfat, Soy Lecithin, Salt, Artificial and Natural Flavors), Sugar, Less Than 2% - Coloring (Includes Blue 1 Lake, Red 40, Yellow 6, Yellow 5, Blue 1, Red 40 Lake, Yellow 6 Lake, Yellow 5 Lake, Blue 2 Lake, Blue 2), Corn Syrup, Dextrin, Cornstarch, Carnauba Wax), Sunflower Oil and/or Corn Oil and/or Canola Oil and/or Safflower Oil, Cane Sugar. CONTAINS: Milk, Soy. Made in a facility that processes egg, wheat, peanuts, and tree nuts.

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Soy Free? Candy Pop, Popcorn M&M's Minis | Spoonful