What are the legal difference here why one of these is defensible because of "not their jurisdiction", and the other is something whole economies get sanctioned over even tho patent jurisdiction also doesn't apply?

The closest to that I could actually find is the World Intellectual Property Organization for trademarks.

But afaik copyrights and patents entirely depend on separate registrations in the individual countries, the only thing the WIPO helps with patents is simplifying the patent application process by filing it in multiple countries for the applicant, but those filings can still be denied by the individual countries. [0]

In that context I just find it a bit curious how American "trademark" theft of EU PDO is handwaved away with "no jurisdiction", yet the American government still insists that its patents, trademarks and IP be respected everywhere around the world, even in places where it too has no jurisdiction.

[0] https://www.legalzoom.com/articles/does-your-us-patent-trade...

edit: Apparently the WTO TRIPS Agreement actually covers geographical indications, and the US is a member to that [1].

[1] https://en.wikipedia.org/wiki/TRIPS_Agreement

This isn't even exclusively an American problem. The EU and Japan do it too, and more countries will start doing that as they start getting stronger domestic creative industries. The more money a country makes from owning copyrighted works, the more protection they will demand from other countries. Hell, the last major copyright term extension (the "Sonny Bono" one in the US) was started by the EU doing the same thing to America. The EU passed a term extension that had a reciprocality requirement: if America didn't agree to the term extension, then American works would enter the public domain in the EU quicker than EU-origin works did. This is a fiendishly clever way to ratchet in term extensions, and it works because the WTO treaties only specify maximums for copyright exceptions, not protection. You're always allowed to go stricter.

As far as I can tell, TRIPS includes the EU PDO protections, so why are US companies selling "fake" EU food products when the US government agreed to respect EU PDO trough TRIPS? Do EU companies simply not sue against that in US courts? I tried looking for cases like that, but I couldn't really find any examples.

> Everyone agreed to the same laws, and agreed to allow foreigners to sue domestic businesses, so it doesn't matter who has jurisdiction over what.

China is also member of TRIPS, don't have Americans the right to sue in China? Why is that not good enough when it's apparently good enough for EU PDO being violated in the US?

I have no idea what hurdles are involved with suing entities in China. I just know that many copyright owners find it too expensive to do so. Presumably, you'd need authorized legal representation in China to sue, which could be even more expensive. Legal translation would also be required, which would also cost money. These are all issues that current international law doesn't cover. Each jurisdiction is allowed to have it's own licensing standards and working languages. The closest thing I could think of to harmonizing that would be something like ISDS (investor-state dispute settlement), a process so onerous even the country that invented it hates them.

There's plenty of other small deviations from WIPO law that member countries have sort-of gotten away with, such as...

1. Moral rights - Canada makes them waivable, which basically makes them meaningless. The US went a step further and never bothered to implement them, arguing that economic rights and contracts were sufficient to protect moral rights. (On the other hand, the US did implement moral rights in VARA, which is why the 5Pointz artists were able to sue and win millions when the property owner badly whitewashed over their authorized graffiti.) 2. Copyright formalities - We spent a literal century trying to get rid of copyright formalities, leading to the world of today where everything is born copyrighted and it is literally impossible for something to fall out of copyright until it has been escheated to the public domain. However, if you do not register your copyright in the US, you cannot sue. Even if you register after-the-fact, you lose your statutory damages if the infringement happened before registration. For the vast majority of infringements, that means there's no money in enforcing your copyright, and all you can really get is some kind of a restraining order on the infringer.

It basically depends on the trade deal. Anywhere in the EU, "Champagne" has a very definite geographic meaning involving a region in France. Likewise "Feta" cheese, "Port" wine etc etc.

But elsewhere it depends on the nature of the deal with the EU.

E.g. Western Cape, South Africa makes good sparkling wine, but the EU flexed muscles in the trade deal, and now they don't call it "Champagne" or even "Champagne-style". 1) Though local "Port" and "Feta" got to keep those names.

I assume that the USA had a stronger hand and got a better deal in this regard.

A quirk of brexit is that the name "Scotch" Whisky may lose EU protection. 2) To Scotland's loss here.

1) https://www.bubbleclub.co.uk/blog/whats-methode-cap-classiqu...

2) https://www.forbes.com/sites/felipeschrieberg/2019/01/16/no-...

https://www.businessforscotland.com/scotch-whiskys-protected...

For Feta:

> According to the relevant EU legislation, only those cheeses produced in a traditional way in particular areas of Greece (Peloponnese, Central Greece, Epirus, Thessaly, Macedonia, Thrace, and the islands of Lesbos and Cephalonia), which are made from sheep's milk, or from a mixture of sheep's and up to 30% of goat's milk from the same area, can be called feta

https://en.wikipedia.org/wiki/Feta

I would assume though that US or ZA feta is _never_ exported and sold anywhere in the EU under that name. That would be against the laws in place where it is sold.

I suppose. Anyway, this is like buying hamburger meat and discovering it's made out of ostrich.

I think there's a big difference between making it illegal to name something because it wasn't manufactured in a certain spot, versus making it illegal because it's a completely different product. I couldn't care less if Feta was made in Greece or not. But Feta from cow's milk isn't Feta, any more than a peanut butter sandwich made with hummus isn't a peanut butter sandwich.

1) Specialist shops will stock imported authentic original Greek Feta

2) you don't - cheap product drives out the original. This is exactly why names like "feta" are protected in the EU.

Indeed: Prosecco is a spumante.