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European Heat Council · Position 09

Issued 2026-06-25

Under Council authority

Geographical indication access

The Council’s position on access to EU geographical indication protection (PDO, PGI, TSG) for small food producers under the new GI regime.

Part I. Findings

The Council records three conditions affecting how Regulation (EU) 2024/1143 on geographical indications applies to small EU food producers. Each is supported by sources cited at the foot of this Position.

Finding 1. The new EU GI regime consolidates and simplifies, but keeps registration as a two-phase national-then-Commission procedure.

Regulation (EU) 2024/1143 entered into force on 13 May 2024 and merges previously separate GI rules for agricultural products, wine, and spirit drinks into a single legal framework with a simplified registration procedure[1]. The Council of the European Union, in its March 2024 adoption press release, described the reform as strengthening protection and clarifying the rules without removing the underlying two-phase structure[2]. Applications continue to be made first to the competent authority of the relevant Member State, which has up to twelve months to scrutinise, and only then forwarded to the Commission for final approval[3],[4].

Finding 2. Registration costs and timelines remain substantial.

Although the application to the Commission itself is free of charge, Member States may charge fees to cover the cost of their own scrutiny, and certification by recognised control bodies is a separate cost borne by producers[5]. Industry analysis records average PDO certification cost at approximately EUR 12,000 with a certification time of approximately 34 months, and average PGI certification at approximately EUR 8,000 with a certification time of approximately 28 months[6]. Independent legal analysis records that, even under the simplified regime, the practical timeline from initial application to operational GI use frequently runs to several years[8].

Finding 3. The producer-group requirement structurally excludes single small producers from GI protection except in narrow circumstances.

Regulation (EU) 2024/1143 retains the requirement that applications for PDO or PGI registration be submitted by a producer group, defined as an association of producers of the same product[1]. A single producer may submit an application only where they are demonstrably the only producer willing to do so within the relevant area[7]. For traditional specialities guaranteed, a single producer may submit where they are the only producer of the product in question[9]. The practical effect is that a single small producer whose product is regionally distinctive but who operates without a formed producer group cannot easily access GI protection, regardless of the product’s genuine geographical link.

Part II. Position

On the basis of these Findings the Council holds that:

  1. The Council supports the principle of geographical indications as a recognition of genuine territorial and cultural identity in food. The Council does not advocate for the dilution of GI criteria or for a relaxation of the requirement that GI claims rest on real production link.
  2. The Council holds that the producer-group requirement, as currently designed, structurally excludes single small producers from GI protection in cases where their product is clearly geographically distinctive but no group has been or can practically be formed. The result is that genuine geographical identity goes unprotected because of an organisational threshold rather than a substantive one.
  3. The Council holds that the registration cost and timeline profile, while reduced under the new regime, remain disproportionate for small producers operating at single-digit or low-double-digit annual turnover figures. The Commission’s administrative simplification work should continue, and Member State fee structures should reflect producer scale.

Part III. Commitments

The Council will:

  1. Track Commission implementing acts under Regulation (EU) 2024/1143 and successor instruments (2025/26, 2025/27, 2025/29) and publish summaries when materially affecting small producer access.
  2. Submit comment in EU and Member State consultations on GI procedural simplification, fee structure, and producer-group requirements where the impact on small producers is material.
  3. Where members hold or are pursuing GI status, document the practical procedural experience so that the Council’s consultation submissions are grounded in producer-level evidence.

Revision

This Position will be reviewed annually, or sooner if Regulation (EU) 2024/1143 is materially amended, if the Commission publishes new implementing acts changing GI procedural costs, or if Member State fee structures are materially revised.

Sources

  1. [1]Regulation (EU) 2024/1143 of the European Parliament and of the Council on geographical indications for wine, spirit drinks and agricultural products, traditional specialities guaranteed and optional quality terms, entered into force 13 May 2024. https://eur-lex.europa.eu/eli/reg/2024/1143/oj/eng
  2. [2]Council of the European Union, Council adopts law to strengthen protection for geographical indications for foods and drinks, press release 26 March 2024. https://www.consilium.europa.eu/en/press/press-releases/2024/03/26/council-adopts-law-to-strengthen-protection-for-geographical-indications-for-foods-and-drinks/
  3. [3]European Commission, Geographical indications and quality schemes explained (Agriculture and Rural Development Directorate-General). https://agriculture.ec.europa.eu/farming/geographical-indications-and-quality-schemes/geographical-indications-and-quality-schemes-explained_en
  4. [4]European Commission, Registration of the name of a GI product (procedural guidance). https://agriculture.ec.europa.eu/farming/geographical-indications-and-quality-schemes/registration-name-gi-product_en
  5. [5]Wallonie public service, Apply for recognition or certification as a European PDO, PGI or TSG quality label (Member State application guidance). https://www.wallonie.be/en/demarches/apply-recognition-or-certification-european-pdo-pgi-or-tsg-quality-label
  6. [6]Industry analysis of PDO and PGI certification cost and timeline data (PDO ~EUR 12,000 / ~34 months; PGI ~EUR 8,000 / ~28 months). https://bhooc.com/blogs/articles/pdo-and-pgi-certification-process-explained
  7. [7]Institut National de l'Origine et de la Qualité (INAO), Administrative simplification: FAQs on the new European GI regulation (Regulation (EU) 2024/1143) — guidance from a national competent authority on producer-group requirements. https://www.inao.gouv.fr/en/info-faq-rue-2024-1143
  8. [8]Bird & Bird, The reform on the protection of geographical indications in the EU (independent legal analysis). https://www.twobirds.com/-/media/new-website-content/insights/pdfs/bird-bird-alert_the-reform-on-the-protection-of-geographical-indications-in-the-eu.pdf
  9. [9]EUR-Lex, Geographical Indications and Designations of Origin (summary of EU legislation). https://eur-lex.europa.eu/EN/legal-content/summary/geographical-indications-and-designations-of-origin.html

Issued under Council authority. European Heat Council, 2026-06-25.

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