An increasing number of trade agreements contains regulations on geographical indications (GIs). The European Union is one of the main proponents of including them in such agreements. It also aims to raise the protection to the level guaranteed in the EU. Transatlantic Trade and Investment Partnership (TTIP), under negotiation since July 2013, resulted in a return to the discussion of the desired scope and level of protection of GIs. The aim of the article is to assess whether the current level of GI protection in the EU and US is sufficient to secure the rights of GI holders and to indicate the roots of tensions in this area between the two parties. The research was carriedn out through the studies of literature and the critical analysis of the legal systems of the two parties of TTIP as compared to the multilateral system of GI protection guaranteed by the WTO Agreement on Trade-Related Aspects of Intellectual Property Rights (TRIPS). The results show that the European system gives the producers of GI much greater protection than other countries, including the US and other WTO members. As a result, the EU desires to raise the international standards to the EU levels. One of the reasons of stronger protection of GI holders’ rights in the EU is the economic significance of the market for GI products. Other reasons include political, social and cultural differences – and these are especially difficult to overcome in the course of trade negotiations.

An increasing number of trade agreements contains regulations on geographical indications (GIs). The European Union is one of the main proponents of including them in such agreements. It also aims to raise the protection to the level guaranteed in the EU. Transatlantic Trade and Investment Partnership (TTIP), under negotiation since July 2013, resulted in a return to the discussion of the desired scope and level of protection of GIs. The aim of the article is to assess whether the current level of GI protection in the EU and US is sufficient to secure the rights of GI holders and to indicate the roots of tensions in this area between the two parties. The research was carriedn out through the studies of literature and the critical analysis of the legal systems of the two parties of TTIP as compared to the multilateral system of GI protection guaranteed by the WTO Agreement on Trade-Related Aspects of Intellectual Property Rights (TRIPS). The results show that the European system gives the producers of GI much greater protection than other countries, including the US and other WTO members. As a result, the EU desires to raise the international standards to the EU levels. One of the reasons of stronger protection of GI holders’ rights in the EU is the economic significance of the market for GI products. Other reasons include political, social and cultural differences – and these are especially difficult to overcome in the course of trade negotiations.