Why California is allowed to use Europe’s protected wine labels

Champagne, Chablis, Sherry, Chianti… these are all European wine labels which can only be used if a wine is produced in a certain region, and with a certain method. Champagne can only be produced in the Champagne region, using the méthode champenoise. Sherry is only Sherry if it comes from the Sherry Triangle in southern Spain. Chablis must be made in the Chablis region, using exclusively Chardonnay grapes. Chianti and other famous names have similar requirements.

These rules are not just customary, but enshrined in national laws, EU-regulation and international trade agreements. And yet to this day California winemakers like Corbel, Cook’s, André or Fairbank are legally allowed to use the aforementioned names on their labels. Why? The answer lies in the history of US-European trade relationships.

The case of Champagne perfectly exemplifies the situation. California has produced sparkling wines since the 1860’s, and, not out of malice or confusion, has called those wines ‘Champagne’, usually along with an indication that the wine was from California.

France sought to put an end to this practice in 1891, when it was one of 55 countries to sign the Madrid Agreement, the first international treaty designed to protect trademark rights. The United States, however, did not enter the agreement, therefore allowing the Californian labeling practices to continue. In fact, as global trade expanded in the early twentieth century and demand for French Champagne increased, more and more Californian winemakers started using the ‘Champagne’ label in order to reap the benefits of the expanding market.

The next agreement supposed to put an end to this was the Treaty of Versailles, at the end of World War I. It addressed the mislabeling of wine and brandy and, while this was mainly designed to resolve disputes between France and Germany, all nations party to the agreement were held to the same standards. This time, the United States signed the treaty – but the Senate never ratified it.

At the time, this wasn’t a big concern for the Champenois: prohibition was about to put California winemakers out of business anyway, and other growing markets were demanding attention.

Californian wine production only recovered in the 1970’s, when production of cheap wines bearing labels such as ‘Champagne’, ‘Burgundy’, ‘Chianti’ and ‘Chablis’ skyrocketed. Once more, European producers were furious, so the European Commission sought to finally reach a valid agreement with the US on this matter.

Negotiations started in 1983 and lasted for more than two decades, but in 2005 the two parties finally reached a consensus. The US agreed not to use labels such as ‘Champagne’, ‘Chablis’ or ‘Sherry’ anymore, in exchange for easier trade restrictions. Unless a winemaker was already using the label, therefore, guaranteeing a loophole that allowed some producers to continue the practice.

Most producers have nevertheless stopped using European labels for their Californian-made wine. The last years have instead given rise to a new and interesting trend: some Californian wineries have now opened production facilities in Champagne, in order to produce real Champagne under their name.

Overall, the problem is not as big as one might think. Quality producers usually have an incentive to develop their own labels. Furthermore, knowledgeable consumers know the difference between ‘California Champagne’ and the real deal. Nevertheless, we should hope that Europe’s winemaking heritage will be able to rely on more complete protection in the future.


Jonas Vallone


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