It's probably made with cocoa powder but not cocoa butter, which is actually a better thing for a frozen dessert because it's hard to get cocoa butter to melt in your mouth when it's that cold.
The coating portion of the ingredients section is
coating (sugar, chocolate, coconut oil, Dutch processed cocoa powder, soybean oil, cocoa butter, dairy oil, soy lecithin, artificial flavors)
https://www.fda.gov/ICECI/ComplianceManuals/CompliancePolicyGuidanceManual/ucm074446.htm
Blame the chocolate lobby. The industry only wants actual chocolate to be labelled chocolate. Foods which contain cocoa but do not contain the necessary ingredients to be considered chocolate (ie, typical chocolate bar with cocoa, one of a specific set of fats, and one of a specific set of sugars in specific proportions) may not be labeled "chocolate" except where consumers have long expected that to be the case. So chocolate pudding, as an example, isn't "chocolate" by definition, but is still allowed to be called "chocolate pudding" because it's been that way for so long.
The FDA may fine food producers who label cocoa containing items as "chocolate" if they do not match the expected definition of chocolate.
Thus, it's a "chocolatey" coating, not a chocolate coating. Get a real chocolate coated ice cream bar and compare the two - this one is easy to bite and consume without the chocolate flaking off or being hard to bite through, while an icecream bar with real chocolate has to have such a thin shell that it has very little chocolate flavor, or it cracks and is hard to bite through.
