Argentina is caught in a complex web of trade agreements that may conflict with each other, highlighting what some call the « war on terroir ». This term refers to a long-standing debate between two trade models: one favored by Europe, which protects products tied to a specific region and tradition, and another favored by the United States, which allows more flexibility in the use of product names. Argentina has committed to both the European Union and the United States, creating a potential conflict in how it regulates product names, particularly for cheeses.
Since May 1st, 2026, Argentina must provisionally protect 344 European geographical indications, including 63 from France, on its territory. This follows an earlier promise to the United States not to block American cheeses labeled as « camembert », « brie » or « emmental ». These two commitments are difficult to reconcile. The main issue is that Argentina's situation reflects a broader strategy by the U.S., which is using trade agreements to prevent the European model of protecting geographical indications from taking hold in new markets.
In January 2026, the European Union and Mercosur signed two agreements: a comprehensive partnership agreement that still needs ratification by all member states, and an interim trade agreement covering areas under Brussels' exclusive control. This explains why the « geographical indications » section is already in effect. It is included in Chapter 13 of the agreement, which focuses on intellectual property and protects European geographical indications against direct copying and even mentions like « cheese in the style of Roquefort ».
On February 5, 2026, Argentina and the United States signed the Agreement on Reciprocal Trade and Investment (ARTI), which allows American cheeses and cold cuts to enter Argentina under specific names without facing customs duties. The agreement must be ratified by the Argentine Congress, and the U.S. has been pushing for its approval. The ARTI has already had political effects, as the U.S. removed Argentina from its priority watch list, where it had been for years over intellectual property issues, and now places the EU on a similar list.
The « war on terroir » was popularized by economist Tim Josling in 2006, referring to the conflict between the European model, which protects products tied to a specific place and tradition, and the American model, which allows more flexibility in the use of product names. This disagreement has led to legal disputes, including at the World Trade Organization (WTO). The WTO's TRIPS agreement offers minimal protection for geographical indications, but the EU has been pushing for stronger protection in its trade agreements.
The U.S. appears to be trying to lock in markets before the European model becomes established. This strategy could create conflicts with EU norms, especially if Argentina ratifies the ARTI. If the EU-Mercosur agreement is not ratified, the EU could lose significant market access and credibility. The agreement includes commitments to human rights, environmental protection, and the Paris climate agreement, which distinguish it from potential agreements with the U.S. or China.
To avoid this, the EU should accelerate the ratification of the agreement with Mercosur. While most Mercosur countries have already ratified the agreement, the EU process is expected to be longer. Argentina could face pressure from both the EU and its South American partners, as the Mercosur bloc has rules against individual countries signing separate trade agreements with third parties. This situation highlights the need for the EU to act quickly to preserve its commercial and normative influence in the region.
European and U.S. Trade Agreements Clash Over Protection of Geographical Indications in Argentina
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