Confused By PGIs, TSGs, PDOs, DOCs….What Does It All Mean?
“Like everything else about the European Union, DOP legislation is very boring but very important: quite simply, there is a huge amount of money at stake.”John Dickie, Delizia! The Epic History Of The Italians And Their Food
Post-Brexit update to the post below – April 2021
If you are either based in the UK, or are importing or exporting to the UK you will be affected by Brexit with regard to Geographical Indicators (GIs). Otherwise, everything remains the same.
So far no agreement
UK GIs and products from the EU being sold in the UK are covered by the EU-UK Trade and Cooperation Agreement (TCA). Surprise, surprise, no agreement was reached on this during the Brexit negotiations, but there is a review agreement which allows ‘discussions to continue’.
Products which have protected status as of 31 December 2020
British products with protected status as of 31 December 2020 under the EU scheme will continue to be protected in EU. Equally, European products which had EU protected status up until that date will get the UK equivalent protected status.
New and pending applications from 1 January 2021 on
New and pending applications will have to apply to the EU in the usual way, and, if they want to be sold in the Great Britain (this doesn’t apply to Northern Ireland which continues with the EU system) they will have to make a separate application to the Department of Environment, Food and Rural Affairs (DEFRA). The British system has three identical GI designations: PDO, PGI and TSG (see the main body of this post for a more detailed explanation of these terms).
DEFRA has issued new UK GI logos for use on products. Where the use of the logo is mandatory, and the product has been registered under the EU scheme prior to 1 January 2021, the producer has until 1 January 2024 to begin using the logo.
These logos are available of download on the Gov.uk website.
Products from outside the UK, and UK products going to non-EU countries
Products from outside the EU have always been able to apply to the EU for GI protection under the EU scheme. From now on, non-EU producers wishing to sell with GI protection within the UK can apply to DEFRA for the same. It seems likely that in future there will be a increasing negotiation with non-EU trading partners with regard to GI status.
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The background to Geographical Indicators – why are they important?
They help reduce fraud
Throughout Saucy Dressings there are quite a few foods described which have earned one or another of these ‘protected denominations’, or ‘Geographical Indications’ as they are known in political circles, but what, honestly, do they all mean and is it important?
The answer is a resounding YES!!! but only if their legislation and enforcement have teeth.
The olive oil industry gives an excellent example as to why.
New Yorker columnist, Tom Mueller, describes an interview with Flavio Zaramella, the president of the Mastri Oleari, where he points to a supermarket bottle of olive oil and explodes vehemently:
“This is what nearly everyone in the world thinks is extra virgin olive oil! This stuff is killing quality oil, and putting honest oil-makers out of business. In wine you can trust the label… “
Zaramella then goes on to identify the headquarters of oil fraud throughout the Mediterranean, naming refineries and factories in Lugano, Switzerland; Málaga, Spain; Sfax in Tunisia, and elsewhere throughout the Mediterranean where bogus extra virgins were fabricated, and to explain why the US was the best place on earth to sell adulterated oil. He also tells Mueller,
“My fight is a civic responsibility to the thousands of honest oil-makers who can hardly make a living in this distorted market, and to the millions of consumers who are being deprived of the therapeutic qualities of olive oil…Great oil is the essence of the Mediterranean diet. Bad oil isn’t just a deception, it’s a crime against public health”
What is the purpose of these laws?
It is the clear and stated purpose of the European laws of protection specifically to support produce from rural areas, especially in cases where quality is a passion. Less directly, the hope is that, by supporting farmers and other artisan industries based in country areas, jobs will be created and migration to cities will be reduced. It is also seen as an additional reliable source of information for the consumer. In the olive oil industry so far as I can tell only Kalamata olive oil has achieved a DOP, with the result described above for the olive oil industry, while many other products have benefited from the protection.
Are they protectionist?
Of course, there are some criticisms of these laws mostly in terms of their being protectionist. For example, one concern is that barriers to entry are created which put potential competitors at a disadvantage. However, this didn’t stop a Japanese whisky producer, Suntory, from winning the distiller of the year award last year.
Of course, there are, as you would expect, bones of contention. The Danes, for example, (one of the largest producers of feta-like cheese) aren’t happy that Greece has been granted protection for feta.
Do the landowners rather than the artisans benefit most?
Another concern voiced by the opponents to the protected designations are that landowners within these areas benefit. But this smacks of the triumph of neighbour envy over concern for the public good. What is the fortuitous financial gain of a few landowners when weighted against the mass deception of the consumers of a whole continent? The peevish cry ‘it isn’t fair’ isn’t very grown up when the issue concerns what we all eat and drink.
And the effect of these laws isn’t just limited to Europe. Most products covered are European, but some non-European products are also covered by a special agreement. And consumers in other continents set store by the European designations.
The main problem is lack of teeth
But the real problem is the lack of teeth. Yes, theoretically, the protected designations are assigned the same protection as intellectual property under customs regulations laws. But, that established, the important aspects are the enforcement and the public awareness.
In 2011 the European Court of Auditors published a report, Do the design and management of the Geographical Indications Scheme allow it to be effective? . It concluded that there was more to be done on both enforcement and awareness counts.
On enforcement the Auditors’ report commented:
“most of the national authorities audited do not carry out regular checks in view in view of detecting and suppressing [disallowed] practices”
“The commission does not monitor closely the implementation of the GI scheme in the member states. No audits on the GI scheme have been carried out so far”
On awareness they pronounced:
“the potential applicants are often not aware of the scheme or are discouraged by the lengthy application procedures”
“consumer recognition of the scheme and its symbols is very low”
In other words in 2011 it wasn’t widely enforced, or widely recognised. In fact, the Auditors couldn’t have been more damning.
But it’s easy to bash the bureaucrats. In fact everyone involved – producers, retailers, the hospitality industry, to say nothing of those who care about the food and drink they put into their body, and those who like to enjoy the process of doing so – can help. It’s one of the reasons the designations are specified (often with a description of the process and ingredients which justify them) on Saucy Dressings. And over the last few years great progress has been made.
We should be more aware of their value
So much so that now these designations are at risk we are finally waking up to their potential value. American firms may, under new trading proposals, be allowed to flood Europe with imitation products with similar names. The Transatlantic Trade and Investment Partnership (TTIP) would merge the US and the EU into a single market (sounds radical… why haven’t we heard more about this?). Apparently the Germans are particularly concerned. According to Anna Sauerbrey, writing in Der Tagesspiegel, the idea of a Nuremberg rostbratwurst coming from Kentucky is a wound to the ‘German soul’. But on the other hand, US firms are just as worried that they will no longer be able to bandy about descriptions such as ‘Champagne’ or ‘Cheddar’ with impunity within the States, so quite how these new arrangements would work is still not clear. UPDATE: 2019: an EU Council decision of 15 April 2019 states that ‘the negotiating directives for the TTIP are obsolete and no longer relevant.’ That is to say that the TTIP is officially dead… for the moment.
An element of hypocrisy – mozzarella made from British milk
Nevertheless, Sauerbrey argues that European producers hypocritically uphold the superiority of their products giving the example that mozzarella is often made from milk from the UK, that consumers are “living in a world of illusion”. Of course, as we’ve seen above, the designations need to be more strictly imposed, but many other examples of support for producers striving for excellence sprout like mushrooms (unprotected) throughout this blog. I don’t see why the regulations can’t be applied equally, and stringently, on both sides of the Atlantic to everyone’s benefit – the quality of the rostbratwurst would remain, and maybe that of Kentucky fried chicken would improve….
Tough – TSG = Traditional Speciality Guaranteed
This denomination is intended for foods of a ‘traditional’ character achieved either because of how it is produced, or due to its composition. Gloucester Old Spot pork has achieved this denomination.
Tougher – PGI = Protected Geographical Indication (IGP in Italian, French and Spanish)
This is an EU-regulated designation. Stornoway black pudding (Morcilla de Burgos which is a Spanish black pudding as applied, application pending), Plymouth Gin, and Sardinian lamb are examples. It’s not as difficult to obtain as PDO but getting there. Not only does it have to be closely linked with its particular area, but also at least one stage in its production, process, or preparation must take place there.
Toughest – PDO = Protected Designation of Origin (DOP in Italian and Spanish, AOP in French)
This is an EU-regulated, strictly examined, designation – as difficult to achieve as France’s own Appellation Controllée (see below). Most stages of production and preparation must take place in the specific area. On this blog there are posts on jamón ibérico and jamón serrano, Jersey Royal potatoes and Scotch whisky, which all enjoy this denomination. In the case of a particular cheese, for example, the label might indicate that the cheese must be made in a particular – for example in the case of Stilton from Leicestershire, Derbyshire and Nottinghamshire. The type of milk, the breed of cattle or sheep, and the size and shape of the moulds are all likely to be specified.
AOC = Appellation d’Origine Controllée
France’s own version of PDO – well recognised even outside France, especially in the wine industry
DOC = Denominazione di Origine Controllata
Italy’s own version of PDO. Less well known than the French AOC. Some reports say the system is open to abuse….
DO = Denominación de Origen
Spain’s own version of PDO