Italian sounding: the fake-Italian food industry

Treat the headline number carefully. The 120 billion euro figure is an industry estimate produced by Coldiretti and Filiera Italia of the turnover of Italian-evoking products worldwide, not an official statistic, and it sweeps in goods nobody presents as Italian. The comparison point is firm: Italian agri-food exports recorded by ISTAT passed 65 billion euro in 2024, a record. Even a heavily discounted estimate leaves the structural fact intact: most cheese sold worldwide under Italian names is made outside Italy, and in several markets the local version predates living memory and outsells the original many times over. The interesting question is not whether the imitation is large. It is which parts of it are illegal, which are merely misleading, and which are entirely lawful.

The catalogue repeats itself across markets. Translated near-copies of protected names: Parmesan in the US and UK, Parmesão in Brazil, Reggianito in Argentina, domestic "Romano" made from cow's milk rather than sheep, Asiago from Wisconsin. Portmanteau names that gesture rather than copy, like Bavaria's Cambozola, an avowed cross between camembert and gorgonzola. The qualifier of convenience: "San Marzano style" tomatoes, "Italian style seasoning", "balsamic style glaze". San Marzano is worth pausing on, because it is also a legitimate tomato variety name that anyone may grow anywhere; the protected item is Pomodoro San Marzano dell'Agro Sarnese-Nocerino PDO, registered in 1996, a small crop from a defined stretch of Campania, dwarfed by the volume sold globally under the name. And then the purely visual register: tricolour packaging, cypress hills, a Vespa, an invented surname attached to food made two thousand kilometres away.

The European courts have drawn the lines. In Case C-132/05, Commission v Germany, decided on 26 February 2008, the Court of Justice dismissed the Commission's action because Germany was not obliged to prosecute its own producers of its own motion, but it held that the word "Parmesan" evokes the protected name Parmigiano Reggiano and rejected the argument that it had become generic. In Case C-87/97, Gorgonzola v Cambozola, decided on 4 March 1999, it held that phonetic and visual similarity can amount to evocation even where the true origin is stated on the label. Case C-490/19 (Morbier, 2020) extended the principle to copying a product's distinctive appearance. Case C-432/18 (2019) marks the limit in the other direction: the protection of Aceto Balsamico di Modena PGI does not extend to the non-geographical words "aceto" and "balsamico", which remain free to use.

Outside the EU, a PDO buys far less than people assume. In the United States several Italian cheese names are treated as generic or semi-generic and carry their own federal standards of identity: 21 CFR 133.165 defines "parmesan and reggiano cheese" as an American cheese cured for not less than ten months. Romano, asiago, gorgonzola, fontina and provolone have equivalents. Protection abroad therefore has to be negotiated market by market: CETA with Canada, applied from 2017, protects many names but grandfathers existing users of Parmesan, Asiago, Fontina and Gorgonzola; the EU-Japan agreement of 2019 and the EU-China geographical indications agreement, in force since 1 March 2021 with one hundred names protected each way, protect fully. There is no equivalent instrument with the United States, where the Consortium for Common Food Names lobbies steadily to keep the names generic.

Buying the real thing is mostly a matter of learning four or five physical marks. Start with the EU symbol, red and yellow for PDO and blue and yellow for PGI, printed with the registered name in full. On a Parmigiano Reggiano wheel, the rind carries dotted lettering all around the side plus the dairy's number and the month and year of production, and an oval fire brand applied only after the twelve-month inspection. Prosciutto di Parma carries a five-pointed ducal crown burnt into the skin; San Daniele keeps its trotter attached and is branded SD. Aceto Balsamico Tradizionale di Modena PDO is sold only in the 100 ml bottle designed by Giorgetto Giugiaro, is a minimum of twelve years old and twenty-five for extravecchio, and contains nothing but cooked grape must. A three-euro "balsamic glaze" with caramel and thickener is a different product entirely. On olive oil, read the back: "blend of olive oils of EU origin" is perfectly legal and means the olives were not Italian, while "product of Italy" requires olives harvested and milled in Italy. And treat "imported from Italy" as what it is: a statement about a shipping route, not about a field.