AOSTA, Italy — The 380,000 wheels of Fontina PDO cheese matured each year are tiny in number compared to the millions churned out by more famous rivals — but that doesn’t make the creamy cheese any less important to producers in Valle d’Aosta, a region nestled in the Italian Alps. 

Fontina’s protected designation of origin (PDO) provides consumers at home and abroad a “guarantee of quality and of a short supply chain,” explained Stéphanie Cuaz, of the consortium responsible for protecting the cheese from cheap copycats, as she navigated a hairpin turn on the way to a mountain pasture.

With fewer than a hundred cows, a handful of farm hands and a small house where milk is transformed into cheese, the pasture at the end of the winding road feels far away from global trade tussles its flagship product is embroiled in.

The EU’s scheme to protect the names of local delicacies from replicas produced elsewhere has proved controversial in international trade negotiations.

For instance, in 2023, free trade talks with Australia were swamped by complaints from its cheese producers railing against EU demands that they refrain from using household names like “Mozzarella di Bufala Campana” and “Feta.” 

Fontina was caught in the crossfire, having been included in the list of names the EU wants protected Down Under.

No such protections exist in the U.S., where in the state of Wisconsin alone, there are a dozen “fontina” producers, one of which won bronze at the World Cheese Awards in 2022. 

Europe’s small-time food producers find themselves in a bind: their protected status is vital for promoting their traditional products abroad, but charges of protectionism have soured some trade negotiations. Nonetheless, many of the bloc’s trading partners clearly see the benefits of the system, baking in similar protections for their own products into trade deals.

Protection vs protectionism

Fontina cheese can only be labeled as such if several strict criteria are met. Cows of certain breeds need to be fed with hay of a certain caliber and, crucially, every step of the cheesemaking process must take place within the region’s borders.  

For Cuaz, who grew up on a dairy farm in Doues, a small town of around 500 people perched on the valley side, the protection of the Fontina name is vital to keep farming alive and sufficiently paid in the region. Tucked up against the French and Swiss borders, Valle d’Aosta is Italy’s least populated region, home to just over 120,000 inhabitants speaking a mixture of Italian, French and the local Valdôtain dialect.

Fontina — which with its distinctive nutty flavor can be enjoyed on a charcuterie board, in a fondue, or encased in a veal chop — is one of over 3,600 foods, wines, and spirits registered under the EU’s geographical indications (GI) system. This protects the names of products that are uniquely linked to a specific region. The idea is to make them easier to promote and keep small producers competitive.

In the EU alone, GI products bring in €75 billion in annual revenue and command a price that’s 2.23 times higher than those without the status, the bloc’s Agriculture Commissioner Christophe Hansen proclaimed earlier this year. He called the scheme a “true EU success story.”

The GI system is predominantly used in gastronomic powerhouses like Italy and France, and Hansen hopes to promote uptake in the eastern half of the bloc. 

Italy has the most geographical indications in the world, accounting for €20 billion in turnover, the country’s Agriculture Minister Francesco Lollobrigida pointed out, describing the system as an “extraordinary value multiplier.”

‘Nothing more than a trade barrier’

While several trading partners apparently share the enthusiasm of Hansen and Lollobrigida  — the EU’s trade agreements with countries from South Korea to Central America and Canada include protections for selected GIs — others view the protections as, well, protectionist.

The U.S. has long been the system’s most vocal critic, with the Trade Representative’s annual report on intellectual property protection calling it out as “highly concerning” and “harmful.”

Washington argues that the rules undermine existing trademarks and that product names like “fontina,” “parmesan” and “feta” are common and shouldn’t be reserved for use by certain regions.

That reflects the U.S. dairy industry’s resentment towards Europe’s GIs: Krysta Harden, U.S. Dairy Export Council president, argued they are “nothing more than a trade barrier dressed up as intellectual property protection.” Meanwhile, the National Milk Producers’ Federation blames the scheme, at least in part, for the U.S. agri-food trade deficit. 

American opposition to the system doesn’t stop at its own trade relationship with the EU. The U.S. Trade Representative’s Office also accused the EU of pressuring trading partners to block certain imports and vowed to combat the bloc’s “aggressive promotion of its exclusionary GI policies.”

Doubling Down

Unfazed by the criticism, Hansen continues to tout geographical indications as vital in the EU’s ongoing trade negotiations with other countries. 

The EU’s long-awaited trade accord with the Latin American Mercosur bloc is heading toward ratification and includes GI protections for both sides. Speaking in Brazil last month, Hansen went out of his way to praise his hosts for protecting canastra, a highland cheese, and cachaça, a sugarcane liquor, against imitations. 

Fifty-eight of the GIs protected under the agreement are Italian, Lollobrigida told POLITICO. This protects Italy’s reputation for high-quality food, he said, and ensures “that Mercosur citizens receive top-quality products.”

The EU recently concluded a deal with Indonesia which will protect more than 200 EU products, and a geographical indication agreement is actively being discussed in talks on a free-trade deal with India that both sides hope to wrap up this year. As negotiations with Australia pick up once again, the issue of GI cheeses is expected to return to the spotlight.

The U.S. pushback on GIs in other countries has fallen on deaf ears, argued John Clarke, the EU’s former lead agriculture negotiator. He criticized detractors for peddling “specious arguments which bear no relationship to intellectual property rights.”

American claims that some terms are universally generic are “illegitimate” and ultimately “very unsuccessful,” in Clarke’s view.

“They came too late to the party,” he said, “and their arguments were not very convincing from a legal point of view.”

Culture and commerce 

The uptake of GIs in other countries demonstrates the additional value the schemes can bring for rural communities and cultural heritage, Clarke posited. 

In Valle d’Aosta, the GI system “keeps people and maybe also young farmers linked to this region,” argued Cuaz, adding that young people leaving rural areas in favor of urban centers is a real problem for her region.

From tournaments to find the “Queen” of the herd that are a highlight of summer weekends to the “Désarpa” parade marking the end of the season as cows return to the valley from their Alpine pastures, Fontina cheese production keeps traditions alive in the tiny region every year. The dairy industry even plays a role in making use of abandoned copper mines, where thousands of cheese wheels mature annually.

Supporters of the GI scheme also point to the food and wine tourism opportunities it offers. Les Cretes vineyard, winery and tasting room represent one such success story. 

The flavors imbued into traditional and native grape varieties by the soil of the Valle d’Aosta’s high-altitude vineyards justify its inclusion as a geographically protected product, explained Monique Salerno, who has worked for the family business for 15 years and is in charge of tastings and events. The premium price on the local wines is vital to keep the producers competitive, given that the steep vines need to be picked by hand, she added.

The business expanded in 2017, building a tasting room to draw tourists to Aymavilles, the town with a population of just over 2,000 that houses much of the vineyard.

Tariff trouble

While American critics have, in Clarke’s view, “lost the war on terroir,” Europe’s small-time food producers are not immune to the rollercoaster of tit-for-tat tariffs that have dominated recent EU-U.S. trade negotiations. 

Like the vast majority of European products heading to the U.S., cheese is subject to a 15 percent blanket tariff. In the meantime, however, organizational mishaps led to some temporary doubling of tariffs on Italian cheeses, angering major producers. 

The whole saga has caused uncertainty, said Ermes Fichet, administrative manager of the Milk and Fontina Producers’ Cooperative. 

The U.S. is Fontina’s largest overseas market, accounting for around 60 percent of direct exports. However, producers aren’t fearing for their livelihoods, yet, as most Fontina cheese isn’t exported at all: an estimated 95 percent of wheels are sent to distributors in Italy.

Rather, the impact of U.S. trade policy is long term. The American market would in theory be able to absorb all of Fontina’s production, Fichet explains, but the sale of similar cheeses at lower prices there makes it difficult to expand market share. 

According to figures released by the USDA’s statistics service, over 5.1 million kilos of “fontina” cheese was produced in Wisconsin alone in 2024. That comes out to a higher volume than the 3.1 million kilos of GI-certified Fontina originating in Valle d’Aosta annually. 

And looking elsewhere isn’t an easy option for the small-time cheese makers, even if future trade agreements include GI recognition.

While markets in countries like Saudi Arabia are growing, they would never close the gap left by U.S. producers if trade ties worsen, said Fichet. 

Responding to the foreign detractors, he highlighted the benefits from the scheme at home. Fontina DOP “allows us to maintain the agricultural reality of certain places … it’s an extra reason to try to help those who are committed to carrying on with a product that is, let’s say, the little flower of the Valle d’Aosta.”