Protected Names Explained: PDO, PGI and TSG

You turn the cheese pack over. Before you reach the cheese itself, there is a small story to unravel: PDO, PGI or TSG. For those of you who read cheese labels as closely as other people read novels, these are promising opening lines.

Behind those letters sit precise commitments about where cheese comes from and how it is made. They include an EU threshold for tradition of 30 years of proven historical use.[1]

The difference matters. PDO ties every production step to a defined place; PGI also protects names linked to a place; TSG protects a traditional recipe or production method without requiring a geographical link. Protection follows the law of the market where the name is used, so EU registration and protection elsewhere are separate questions.[1,2,7]

Three initials, two questions to take shopping

Where must your cheese come from? Which production rules must its maker follow? Those two questions help you understand the EU schemes below, which also apply to registered names sold in Northern Ireland.[1,2]

PDO, protected designation of origin: every production step belongs in the defined area. The cheese's qualities or characteristics must be essentially or exclusively attributable to that geographical environment, including its natural and human factors. You will find the detailed requirements behind the registered name in its product specification.[1]

PGI, protected geographical indication: at least one production step belongs in the defined area. A quality, reputation or other characteristic must be essentially attributable to geographical origin. The specification tells you exactly which stages must happen in that place.[1]

TSG, traditional speciality guaranteed: the focus here is tradition, through production methods, composition or ingredients. EU law requires at least 30 years of proven historical use to establish that tradition. Production need not stay within a particular geographical area, but every producer must meet the registered specification.[1]

When you compare names, keep that distinction in view. PDO and PGI answer questions about geographical origin; TSG answers a question about tradition.[1]

The EU's 2024 rules: put these dates in order

The legal timetable begins with Regulation (EU) 2024/1143, adopted on 11 April 2024 and published on 23 April 2024. It entered into force and generally applied from 13 May 2024. Articles 10(4), 10(5), 39(1) and 45 applied from 1 January 2025.[1]

The European Commission makes EU registration decisions. The EU Intellectual Property Office, EUIPO, keeps the Union register of geographical indications, recording registrations, amendments and cancellations. Traditional specialities guaranteed follow their own provisions, so distinguish a registered name from a pending application or cancelled entry when you investigate a label.[1]

Where does your cheese's name have protection?

A name can gain protection through registration or recognition by treaty. These are different routes, not interchangeable promises. The dates in this table concern the scheme or instrument, rather than an individual cheese's registration.

Place and scheme	What it protects	Who handles registration	Legal basis and start date	Record date
EU PDO and PGI	Geographical names, with different production links to place	European Commission; EUIPO maintains GI register	Regulation (EU) 2024/1143; 13 May 2024	6 November 2026
EU TSG	Traditional specification, without a required geographical link	European Commission	Regulation (EU) 2024/1143; 13 May 2024	6 November 2026
Great Britain PDO, PGI and TSG	Registered names across England, Scotland and Wales under UK GI schemes	Defra	UK GI schemes from 1 January 2021	Guidance: 6 November 2026 [2]
Northern Ireland EU schemes	EU registered names sold in Northern Ireland	EU registration system	Windsor Framework	Guidance: 6 November 2026 [2]
Switzerland AOP and IGP	Domestic designations of origin and geographical indications	Federal Office for Agriculture	Ordinance RS 910.12	Register: 6 November 2026 [5]

Sources: EU [1]; Great Britain and Northern Ireland [2]; Switzerland [5].

Belfast or Great Britain? Follow the destination

Where the cheese is going matters. Great Britain has its own registers, published by Defra; Northern Ireland follows the EU schemes under the Windsor Framework. If you are assessing a name for sale in Belfast, you need the EU position, even when the supplier is based in Great Britain.[2]

Names protected under the EU schemes on 31 December 2020 continued under both systems. New registrations take separate routes: Great Britain producers must secure UK scheme protection before applying to the EU schemes. Northern Ireland producers may apply directly to the EU.[2]

Defra's cheese register listed 284 entries on 6 November 2026. Of those, 281 were registered and three were cancelled.[3]

Switzerland: local roots, protection across borders

Switzerland's domestic cheese register keeps place firmly in the picture. On 6 November 2026, all 12 cheese entries were AOP, with no cheese IGP entries.[5] AOP requires every production stage to take place in the area; IGP requires at least one.

The full names are AOP, appellation d'origine protégée, and IGP, indication géographique protégée. Switzerland registers them through the Federal Office for Agriculture. Foreign names can also receive protection through international agreements.[5]

At the Swiss and EU border, you encounter another legal route. Annex 12 to their agricultural trade agreement protects listed names reciprocally; the agreement introducing it entered into force on 1 December 2011. You need the applicable agreement list, because domestic registration alone does not determine coverage.[6]

That protection extends beyond direct misuse to imitation and evocation. Giving the true origin, translating the protected name or adding words such as 'style' does not, by itself, avoid it. Read both the listed name and any specific exceptions in the agreement.[6]

The logo catches your eye. Give the label a look too

EU and UK symbols identify the relevant scheme, but their placement follows specific rules. For EU agricultural products originating in the Union, the appropriate PDO or PGI symbol is compulsory on labelling. The registered name must appear in the same field of vision, and EU produced TSG products also require the TSG symbol.[1]

The artwork comes with instructions of its own. Commission Implementing Regulation (EU) 2025/26, Article 34 and Annex XVII, sets out how EU symbols are reproduced and requires the registered name to accompany them.[14]

In Great Britain, GB products registered before 1 January 2021 had to carry the relevant UK logo when sold there by 1 January 2024. For GB products registered after 1 January 2021, the logo is required as soon as they go on sale in GB as protected products.[4]

Defra's guidance requires EU logos on EU products registered under the EU schemes when sold in Northern Ireland. Their use in Great Britain is optional. Use the official artwork files and follow the placement rules for your product's origin, registration and market.[4]

EU GI labels must also show the producer or relevant operator's name in the same field of vision as the GI. Products labelled or placed on the market before 14 May 2026 without meeting that requirement may continue to be sold until stocks are exhausted.[1]

Beyond Europe: find the rules at your destination

Once your cheese travels beyond the EU, Great Britain and Switzerland, start with the destination country's law and any applicable agreement. European initials tell you which scheme it belongs to. Local rules determine its protection there.

In the United States, geographical indications can be protected through certification marks, collective marks and trademarks; common law rights are also possible. The USPTO examines US applications. Search the particular name and relevant marks, because EU registration does not itself establish a US right.[7]

In Canada, the Trademarks Act provides GI protection with exceptions. Section 11.17 includes prior use and qualified use provisions for specified cheese names. Read both the protected name entry and the statutory exceptions relevant to that name.[8]

In Australia, IP Australia identifies certification trade marks as the principal mechanism for protecting GIs. For cheese, look at the Australian rights and their scope. Check a treaty's operative date too, before treating promised protection as law.[9]

In New Zealand, IPONZ identifies EU names protected through the EU and New Zealand free trade agreement. Search the New Zealand GI register and read the provisions for the individual name, including any transition. The Australian position does not establish the position in New Zealand.[10]

Codex Alimentarius has a different job. Its General Standard for Cheese, CXS 283-1978, addresses cheese as a food product, and Codex texts are voluntary international standards. Binding duties arise through the relevant national law, including where it incorporates a standard.[11,12]

Pack in hand? Follow the name through three registers

Start with the exact wording on your pack. Keep the accents and any geographical qualifier: those details belong to the name. Then ask two separate questions: is it protected in the intended market, and what production requirements come with it?

1. EU and Northern Ireland: search the name in eAmbrosia. Look at whether the record is registered, applied for or at another procedural stage. Open the registration instrument and product specification, noting the relevant dates. Look for TSG records separately from PDO and PGI records.[1,13]
2. Great Britain: search Defra's Protected geographical food and drink names register. Confirm the status on the individual record and read its specification. Keep cancelled entries separate from registered names. Compare any later EU amendment with the GB record rather than assuming both changed together.[2,3]
3. Switzerland: search the Federal Office for Agriculture's AOP/IGP register and open the product's specification. For a foreign name, also consult the applicable agreement and its current list. Record whether the evidence establishes Swiss domestic registration or recognition under an agreement.[5,6]

Make your work useful next time, too. Save the exact name, jurisdiction, scheme, status, specification version, relevant legal instrument and date of your search. You will have more than a logo to go on: a traceable answer about which name is protected, where, and under which rules.

The Rind Question

Questions people ask

What is the difference between PDO, PGI and TSG?

PDO requires every production step to take place in a defined area, while PGI requires at least one step there. TSG protects a traditional production method, composition or ingredients without requiring a geographical link.

Can a TSG cheese be made outside its place of origin?

TSG production need not be confined to a particular geographical area. Every producer must still meet the registered specification.

Do EU cheese protections apply across the UK?

EU schemes apply in Northern Ireland under the Windsor Framework, while Great Britain has its own registers published by Defra. Names protected under the EU schemes on 31 December 2020 continued under both systems, but new registrations follow separate routes.

Does an EU protected cheese name automatically have protection in the United States?

EU registration does not itself establish a US right. Geographical indications can be protected through certification marks, collective marks and trademarks, with common law rights also possible.

How can I check whether a cheese name is protected?

Search the exact name in eAmbrosia for the EU and Northern Ireland, or in Defra’s Protected geographical food and drink names register for Great Britain. Check the record’s status and read its product specification, as an application or a cancelled entry is not the same as a registered name.

Sources

1. European Parliament and Council. Regulation (EU) 2024/1143 on geographical indications for wine, spirit drinks and agricultural products, as well as traditional specialities guaranteed and optional quality terms for agricultural products. Official Journal, 23 April 2024. Original published text, particularly Articles 2, 21, 22, 37, 46, 49, 52 to 54, 64, 70 and 97.
2. Department for Environment, Food and Rural Affairs. Protected geographical food and drink names: UK GI schemes. Updated 8 March 2024.
3. Department for Environment, Food and Rural Affairs. Adding a logo to a protected food or drink name: follow the rules. Updated 13 March 2025.
4. Swiss Federal Office for Agriculture. AOP / IGP: appellations d'origine et indications géographiques. Published 4 July 2025; live register and scheme explanation.
5. European Union and Swiss Confederation. Agreement on the protection of designations of origin and geographical indications for agricultural products and foodstuffs. Signed 17 May 2011; Official Journal L 297, 16 November 2011. See also the notice of entry into force, Official Journal L 302, 19 November 2011.
6. United States Patent and Trademark Office. Geographical indications protection, and Geographical indications. Official explanatory guidance, retrieved November 2026.
7. Department of Justice Canada. Trademarks Act, section 11.17. R.S.C. 1985, c. T-13; displayed consolidation current to 19 October 2026, last amended 1 April 2025.
8. IP Australia. Trade Marks Manual, section 35.2: Certification trade marks and geographical indications. Updated 11 February 2026.
9. Intellectual Property Office of New Zealand. European Union geographical indications and changes to legislation. Official guidance, retrieved November 2026.
10. FAO and WHO, Codex Alimentarius. Are Codex standards mandatory?. Official explanatory guidance, retrieved November 2026.
11. Codex Alimentarius Commission. General Standard for Cheese, CXS 283-1978. Official standard listing, including amendments adopted in 2024.
12. European Commission. eAmbrosia, geographical indications register. Live public register.
13. European Commission. Commission Implementing Regulation (EU) 2025/26, Article 34 and Annex XVII. Official Journal, 15 January 2025.

Last checked: November 2026

Last checked November 2026.