Why do some US winemakers call their sparkling wines Champagne and we don’t?

The history goes back to the First World War. The first international treaty on the protection of trademarks was the “Madrid Agreement” concluded on April 14, 1891 by the then European countries, but the USA did not accede to this agreement. It was in the Madrid Agreement that the protection of the name “Champagne” appeared.

The 20th century saw an increase in the popularity and sales of champagne on world markets. Many producers, especially from California, have used the name “Champagne” on their labels for sparkling wines. It must be admitted, however, that winemakers distinguished between “domestic Champagne” and “Imported Champagne”. The name “Champagne” was simply synonymous with sparkling wine. The winemakers from Champagne, to put it mildly, were furious, but there was little they could do, because the Madrid Agreement only applied to Europe and the countries that acceded to the agreement.

The case was brought back on the occasion of the Treaty of Versailles that ended the First World War. Article 275 states that only a product from Champagne can be called “champagne”. The treaty was to be binding on all signatories, including the United States, but the US Senate never ratified the treaty. Californian winemakers were still allowed to use the name ‘Champagne’. The French are busy rebuilding vineyards and wineries that were decimated as a result of the war, and with the widespread conviction that due to prohibition in the US, the matter itself was not dealt with in a special way.

This is what one American participant at the Paris conference recalls:

“The French Prime Minister, Georges Clemenceau, brought the wine and offered a toast to the peace and health of the company. After drinking the toast, he turned to me and said, “Better to drink another one, because you won’t get this (wine) when you get home.”

The California wine industry did not really recover until the 1970s, with the increase in production of wine consumption. It was then that California Champagne infuriated French winemakers once again. In 1983, the European Commission and the United States began trade talks on wine. The Comité Interprofessionnel du vin de Champagne (CIVC), a trade group formed in 1941 to organize and protect winemakers during the German occupation, had a lot to say in these negotiations. Negotiations took two decades, but at the end of June 20, 2005, the US and the EU reached an agreement. The US government agreed that California Champagne, Chablis, Sherry, and a half-dozen other names will no longer appear on national wine labels – that is, unless the producer has already used them (SIC!).

If a manufacturer had used (or abused from the French point of view) one of these names before March 10, 2006, he could have continued to use that name indefinitely on his label. “This is morally absurd,” champagne producer and CIVC representative Bruno Paillard told Decanter in 2005.

“It is sad that the United States, now a great wine country, still protects a few producers who abuse the identities of others, rather than using honest labels to provide truthful information to consumers.”

“Moral absurdities” aside, the issue of misleading consumers is more complicated than the CIVC would believe. Nineteenth-century California winemakers, most of whom were immigrants from Europe, called all sparkling wines champagnes. While there were certainly some who wanted to cheat and there was no shortage of falsely labeled wines, advertising and restaurant menus of the time usually made it clear where the “champagne” in question was coming from.

Georges Geiling, who produced Champagne Poznań-Reims in the interwar period in Poznań, had a similar problem, but this is a story for a different story.

Writing these words I used Wikipedia and Joshua Malin’s blog and the article “The Hundred Years Gap That Makes California Champagne Legal”.

Mirek Krasnowski