US-Argentina Pact Threatens European Geographical Indications. Is Parmesan at Risk?

US-Argentina Pact Threatens European Geographical Indications

On 16 February 2026, the Farmers' Journal reported that Article 2.5 of the bilateral US-Argentina trade agreement permits Buenos Aires not to restrict American market access for products carrying protected European names. Specifically: Parmesan, Feta, Camembert, Brie, Emmental, Gorgonzola, and Gouda.

Farm Europe warned that Argentina's move "risks becoming not a shield, but a vulnerability" for EU food name protections.

The problem: two systems, one territory

In the US, names like 'Parmesan', 'Feta', and 'Champagne' are treated as generic terms — anyone can use them. In the EU, these are protected geographical indications (GIs) — only producers from specific regions can use them.

The EU-Mercosur agreement protects these names. Article 13.35(1) states:

'Each Party shall provide, according to its laws and regulations, the legal means for interested parties to prevent: (a) the use of a geographical indication of the other Party listed in Parts 1 and 2 of Annex 13-B [...] that does not originate in the country of origin specified in Annex 13-B.'

Article 13.35(1)(e) goes further — protection applies even when a GI is "used in translation or accompanied by expressions such as 'kind', 'type', 'style', 'imitation' or the like."

The Trump-Milei pact (Art. 2.5) moves in the opposite direction — giving American producers freedom to export 'Parmesan' and 'Feta' to Argentina.

The legal question

Can Argentina simultaneously:

• Protect EU GIs (under the EU-Mercosur agreement)
• Allow the US to use the same names (under the Trump pact)?

The EU-Mercosur deal protects 347 EU geographical indications in Annex 13-B — cheeses, wines, cured meats, oils, spirits. But if American products with the same names are legally on the Argentine market, the protection becomes illusory.

Which products are most at risk?

Based on the confirmed list from Art. 2.5 of the US-Argentina agreement:

The scale of the problem

EU geographical indications generate over EUR 75 billion in annual sales (European Commission data). Italy alone has 58 DOP/IGP products protected in the Mercosur deal. France protects Champagne, Roquefort, Comté, Bordeaux. Spain — Jamón Ibérico, Manchego, Rioja. Greece — Feta. Portugal — Porto.

Defence mechanism: Chapter 21

The EU-Mercosur agreement includes a dispute settlement mechanism (Chapter 21). The EU could theoretically challenge Argentina for breaching GI protection. But proceedings take months, Argentina could argue the US pact covers American products rather than European ones, and enforcement depends on Buenos Aires.

Article 13.35(10) provides that protected GIs "shall not become generic" in the territories of the Parties. Strong legal ground — but it requires enforcement.

What it means

For GI producers: The risk is real and specific. If Wisconsin 'Parmesan' is legally available in Buenos Aires, Argentine consumers may not distinguish it from Parmigiano Reggiano.

For the ratification process: The case for rapid ratification grows stronger. The sooner GI protection enters into force, the harder it becomes to undermine with the US pact. Article 13.35(2)(a) gives protection priority: once in force, conflicting trademarks should be refused or invalidated.

For Argentina: The dilemma is concrete. Buenos Aires must choose: strong European name protection (with EU trade benefits) or an open market for American imitations (with political benefits from Washington).

Sources: Farmers' Journal (16.02.2026), Euractiv, Politico.eu, Vinetur, Farm Europe. EU-Mercosur Agreement: Art. 13.35 (GI protection), Art. 13.35(10) (Non-genericisation), Annex 13-B, Chapter 21 (Dispute Settlement).