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

Is Frosted Donut Holes Soy Free?

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

Bleached Enriched Wheat Flour (Flour, Malted Barley Flour, Niacin, Reduced Iron, Thiamine Mononitrate, Riboflavin, Folic Acid), Sugar, Water, Palm Oil, Partially Hydrogenated Palm Kernel Oil, Cocoa Powder (Processed With Alkali), Soybean Oil, Defatted Soy

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