Some thoughts on the new UK system for geographical indications announced yesterday

“Guidance: Protecting food and drink names from 1 January 2021”…

The UK had said it would “mirror” the EU system. The new announcement confirms the same structure:

•protected designation of origin (PDO)
•protected geographical indication (PGI)
•traditional speciality guaranteed (TSG)…

The new UK logos match the EU’s




1. Use of the logos on labels and packaging is compulsory (in UK) for products registered for protection in the UK although optional for wine and spirits. (Same as with EU logos)

2. The rules are different in Northern Ireland (EU rules apply)

If the product is registered in the EU, the use of EU logos is compulsory for sale in the EU (optional for wines and spirits)

Some producers might want to save labelling/packaging costs by printing both UK and EU logos for all their products…

Since the UK system “mirrors” the EU’s, will this become an issue in trade talks with countries sceptical about geographical indications, eg US, Australia? We’ll see.

In any case the UK will continue to protect EU names registered before transition-end. So no US “feta”.

Recently there have been more claims that “Scotch” (and other UK names) will lose protection if there is no UK-EU deal.

Here’s why the claims are wrong:…

Finally, “What are geographical indications?”

Hint: they are names, not products…


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More from @CoppetainPU

16 Oct
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It would be wonderful if #AustraliaSolutionNotAvailable started trending


To match Australia-EU deals, the UK needs:

● UK-only tariff quotas for beef, lamb and many other farm products. Not with no deal
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How many bilateral EU-Australia agreements? 20, about half on trade:…


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15 Oct
EU and US statements in the WTO General Council this week cover several interesting issues, including reforming WTO routine work (the stuff that keeps trade flowing as smoothly as possible), developing-country status and more. Here are a few


US statements are also available:…

1. Routine work.

47-members paper (EU+EU27=28)—"Procedural Guidelines for WTO Councils and Committees Addressing Trade Concerns”.

Why “trade concerns”?

A key function of the committees is for countries to air concerns about others’ trade measures

3/13… Image
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15 Oct
Analysis ⬇️

How UK 2021 applied tariffs (Global Tariff™️)—many slightly lower than now—affect middle/low income countries

—Value of preferential tariffs eroded slightly
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—Cameroon, Cote D’Ivoire, Ghana, Kenya not rolled over yet
Tariffs are cut slightly post-transition by converting tariffs in euros to sterling using a low exchange rate and getting rid of low “nuisance” tariffs (below 2%).

Most other eliminated tariffs are not on products that mid/low income countries export.…
In this, the UK is a world leader.

No other country in the world has bothered to give its common-or-garden applied MFN tariffs a brandname.

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1. EMPEROR’S NEW CLOTHES. The fantasy “Australia-style” trade relationship with the EU is in vogue again.

Time for another look at what it means, and why the UK won’t have one.

No deal failure can't be dressed up as success.

Here's Johnson:
2. ECONOMIC COST. Here’s LSE’s @thom_sampson:

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24 Aug
@SarahLudford I'd say it's grandfathering, "what's protected now stays protected", ie only names protected up to the end of the transition remain protected.

(Once the UK has its own system, *new* EU names would be protected if they meet UK criteria.)

But ...
@SarahLudford Article 54 paragraph 2 (on GIs) of the Withdrawal Agreement is legally complicated. The "grandfathered" protection for existing EU names is tied to EU law. If a name no longer qualifies under EU law, the UK will no longer have to protect it.

And ...…
@SarahLudford ... and it is clear that the paragraph on geographical indications can be terminated if there is a new UK-EU trade agreement (the subject of Article 184).

I'm not a lawyer but that's the broad picture as I understand it./end…
Read 4 tweets
19 Aug
1/14—This ⬇️ tweet has generated a lot of comment and some anger. Here’s why it’s WRONG to say—as @_schuermann does—that

1 “UK companies lose their EU protected [geographical indications]” ✖️
2 “ANY country in the world can produce Scotch whisky” ✖️

2/14—To keep this simple let’s to look at, post-Brexit/post-transition, …

● the status of British geographical indications (GIs, which are product *names*) IN THE EU
● their status in the REST OF THE WORLD if protected now
— outside an EU agreement
— via an EU agreement
3/14—BRITISH 🇬🇧 NAMES IN THE EU 🇪🇺 (1):

Protection is secured by registering the names as a “(protected) geographical indication” (PGI or GI) or “protected designation of origin” (PDO). (There’s also a “traditional speciality guaranteed” category)… ImageImageImage
Read 15 tweets

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