Feta cheese is the heart and soul of Greek cuisine. For centuries now Greeks have relied on cheese as their main source of proteins, and since sheep and goats were the main source of milk, feta was the cheese that covered such a need. It should come as no surprise then that Greeks are the number one cheese consumers in the European Union, and that their favorite cheese is feta. Unfortunately market forces have conspired against the cheese by producing bland imitations, this paper will seek to clarify the problem and reestablish the true origin of feta cheese.
Brief History & Process of Cheese:
Man discovered cheese accidentally while transporting milk in canteens made from young calf's or sheep's stomachs. Milk curdling enzymes which are present in the stomachs of an un-weaned animal, acted as the separating enzymes for the milk and created a form of cheese. The accidental discovery of cheese is a landmark in the cheese's history. This paper focuses on a purely Greek cheese, so the history of cheese within Greece will be explored.
Aristotles and Dioskouridis, renown philosophers, talked about mixing milk from the leaves of a fig tree with goats milk and obtaining cheese. Others talked about making cheese by mixing fresh milk with lemon or vinegar, cheese is still made this way in the island of Crete. Greece is not the only country with peculiar cheese manufacturing techniques, in Spain and Portugal dried caper leaves were used as rennet in the manufacturing of their high quality cheese.
A simple explanation on how cheese is made would be that the solids are separated from the liquids in milk by the addition of enzymes, which are most commonly known as rennet or rennin. The addition of enzymes produces whey, a thin layered whitish liquid, and curds, solid clumps. The curds are then concentrated and produce the soft white substance which we know as cheese. The texture, aroma and taste of each cheese is unique, varying with each step of the process. Throughout the process of producing cheese the qualities of its main component milk, are conserved. Thus cheese is very rich source of proteins, fats, vitamins A, D, E, and K, as well as aminoacids, all of which are essential for a balanced and nutritional diet.
Cheese & the Greeks:
Greek eating customs could be said that revolve around cheese. This is very different from the rest of Europe. This difference is also present when contrasted to the other south European countries, which share a similar climate and a great variety products with Greece.
For the Greeks, cheese is not a food supplement, it is food. In Europe cheese is generally consumed after the main dish. In France for example cheese is eaten as dessert, one would never see a Frenchman eat his filet mignon with cheese. The French can not imagine eating cheese at any other moment during the day, not even spreading a soft cheese over their world famous croissants. On the other hand in Italy cheese is served as an appetizer, for example mozzarella al pesto or fresh parmesan cheese with rucula and olive oil. Cheese is not part of the Italians main dish, and if one is thinking about pizza, it should be clarified that the original pizzas from Naples and Sicily did not include cheese as an ingredient. Cheese, anchovies, jam, and all the other ingredients that are known to adorn pizza's were not added until much later when the standard of living increased and these ingredients became affordable.
Contrary to its European counterparts of France and Italy, Greeks consume cheese at all times. Cheese can be had for breakfast, lunch, dinner, alone or with other food. Anybody who has lived or been to Greece knows that the one food that can be eaten any time of the day is "tyropita"- cheese pie.
Even though eating habits around the world have changed, especially since the advent of fast food restaurants, Greeks most common and favorite food is cheese. For breakfast Greeks generally prefer hard or semi-hard cheeses accompanied by a fresh loaf of bread. If they are ever hungry during the day, whether they are at the office, in the fields picking olives or at home, they will stop for a "tyropita" or a "culuri" (the Greek bagel) with cheese to quell their hunger. The first food that is brought to the table during lunch is a fresh slice of feta with olive oil and oregano. In the evening fresh fruit and a little bit of cheese is still the number one choice of a light dinner in Greece.
The Greek's fascination with cheese can be explained through its economic history. Greece was never a rich country, currently it has the lowest GNP per capita of the EU, so their every day diet was frugal. Meat was scarce and expensive, this limited the intake of animal protein to weekends and holidays. Greeks had to find a way to substitute those proteins with something nutritious and not as expensive. Cheese was the answer to the problem, partly due to Greece's limited urbanization. The vast majority of Greeks used to be farmers or have small plots of land-"perivoli". The milk that they got from their limited livestock was conserved by producing cheese with it. Cheese was thus always available to the Greeks who never failed to put it on the table when they sat down to eat. This habit has allowed Greeks to become the highest consumers of cheese within the European Union with an average consumption of 23 kg per person per year. The French with an annual per capita cheese consumption of 22 kg's, are just one kilo behind the Greeks. Of all the cheese consumed by the Greeks 60% of it is soft cheese, and 40% of all cheese consumed is feta. That is to say that for every 10 kg's of cheese that are eaten, 4 kg's are feta cheese.
Greece's economic prosperity has not limited its cheese consumption in the least. Today the combined intake of meat and cheese proteins has turned into a hazard for the average Greek. This combined intake of proteins has led to a significant rise in the level of cholesterol and fat within the Greek population, but as the Greeks say "it is easier to loose your sole than your habit".
FETA Cheese & The GREEKS :
Feta cheese is as old as Greece itself. Homer in one of his memorable works, the Odyssey, describes how the giant sheppard Polythimos, made his cheese. The process described by Homer thousands of years ago, closely resembles the process by which feta cheese is still elaborated in Greece. Despite the fact that thousands of years seperate modern Greece from the Ancient Greece in which Homer lived, the process of making feta remains very similar. Up until 1898 feta was produced and consumed locally in Greece. That same year the first commercialization of feta is registered in the island of Syros, Greece. Until then feta could not be traded commercially due to the lack of a preservative. When brime was introduced as a preservative, the Greek flavour of feta cheese was able to propagate across the world.
The history of Greek cheese does not end with feta. Even though Greece has a mountainous landscape that is ideal for sheep and goats to prosper in, cows have also been a part of Greek cheese history. The availability of sheep and goats allowed for the creation of cheeses based on their milk more easily, but it is a renowned fact that Greece has always had cows as well.
Through Greek mythology we learn that cows were used as sacrifice for the Gods, but more specifically we know about cows through myths about Hercules. Hercules was in charge of cleaning the stables of King Angean, who had a herd of 3,000 oxen whose stable had not been cleaned for more than thirty years. In the myth cows were used for their meat and the oxen were used in the fields for ploughing and for carrying heavy loads.
Despite the fact that cows were available for milking in Greece hundreds of years ago, only in the early 20th century did Greece start producing fresh cow's milk. There is one exception though, and that is the islands of the Cyclades. In these islands, cow milk had been used for producing cheese before mainland Greece ever started producing it and using it for the production of cheese.
The puzzling question is how did the cows get there? The Venetian’s and the Italian’s repeatedly conquered the islands of the Cyclades, therefore becoming protectorates and ducats of these European states for hundreds of years. The conquerors generally brought with them Catholic priests and monks in their effort to convert the predominantly Orthodox population. Catholic monks are renowned for their strong working habits. So not only did they bring their customs and their utensils, they also brought with them their animals which included cows. This is how the islands of Tinos, Naxos and Syros were able to produce their renowned cheeses from cow's milk.
FETA CHEESE- The Process:
Feta is a soft white cheese full of uneven small holes, it does not have an outer layer as some cheese's do. Feta in Greek means slice, the name comes from the cutting of the curd into pieces after elaboration. It used to be called 'barrel' cheese or 'tsadila' cheese. The names came to be because 'tsadila' is the cloth that is used in the process of draining the curd, and 'barrel' because it is usually conserved in barrels or tins full of brime. Feta cheese is stored in rectangular pieces of 1 to 2 kilos, preserved in brime in barrels or tins of 25 to 50 kilos. In the super markets it is sold in indivudual prepackaged pieces, or can be bought from the deli directly from the barrel. Tasty mature feta has the following chemical breakdown: humidity 52%, fat 25-26%, proteins 17%, and salt 1.8-2.75%. Feta cheese matures after a period of 2 months in the brime, and should be conserved in the fridge at 2º-5º celsius. Feta cheese is traditionally made from unpasteurized milk, but can also be produced with pasteurized milk. During curdling no heat is used and the temperature must remain between 24º-36º degrees celcius during the process. The milk used has to be natural or processed sheep's milk, and in some cases even sheep yogurt may be used. After the curdling in complete, the whey is removed and the curd is cut into large pieces and placed in molds to drain., once fully drained it is salted and left to repose in low temperatures. It is then placed in barrels or tins which are filled with brime and is left to mature for no less than 60 days. The production of feta is still a traditional a traditional skill as the salt content, temperature at which the enzymes are added, acidity, way of straining are determined by each cheese maker to give a distinct character to his own particular product.
Protected Designation of Origin (PDO) & its Specifications for Cheese:
The European Union (EU) with its open borders and common currency has united 15 very different countries politically and economically. Socially however the EU will never be able to blend its current or eventual members in one big 'melting pot' like the United States is. Each country, in spite of this union, maintains its individuality with its customs, religion, local tradition and products.
Out of all these the one that needed protection from such an all encompassing union were each country's unique products. For this purpose in 1992 the EU past the regulation 1208, which explicitly clarified under which conditions a product may be determined as a PDO for either its name or its geographic origin. This regulation was established in order to defend the position of a product within its particular market.
The importance of having a product labeled as PDO is that it serves as a guarantee of quality and tradition. In the feta case it would guarantee that the consumer is getting feta cheese made from sheep's and goats milk not partially skimmed cow's milk. Currently only 15% of the consumers within the EU know what PDO stands for.(Mamalakis, 35)
The designation of PDO for a product is not limited only to cheese. Sweets, sausages, a kind of meat produced in a certain area, the water from a particular spring, a fruit, olives, olive oil, and many other products may be PDO. Champagne, Cognac, Roquefort are only some examples of products that enjoy a PDO.
The conditions needed for a cheese to become a Protected Designation of Origin are: A) The cheese must be produced and matured in a specific geographical region. The animals that whose milk is used in making the cheese have to adhere to the predetermined species and they must live, graze and be milked in the same area. B) The use of chemical substances for the maturing and coloring of the cheese is prohibited. The milk must not contain any antibiotics. C) It must be produced in the traditional manner.(Mamalakis, 35)
The specifications are quite clear as to what constitutes a cheese under the label of PDO. Greece has submitted several products to be considered as PDO, amongst them feta cheese. Feta cheese due to its popularity and prominence within the cheese category has encountered several barriers which impede its categorization as a PDO. Greece has managed to protect 20 other cheeses, out of a total of 126 cheeses which are protected as PDO by EU regulation.
If a product is classified as PDO it means that no one in the same country but different area, or abroad may produce the product and give it the protected designation of origin name. When a product is labeled as a PDO both the consumer and the producer are protected and the traditional production and taste of the product is promoted.
Judgement of the European Court of Justice (ECJ):
To obtain the necessary data needed for a possible registration of the name "feta" as a protected designation of origin-"PDO"-or its inclusion in the list of generic names, as demanded by a majority of other Member States, the European Commission arranged for a Eurobarometer survey to be carried out, questioning 12,800 nationals of the twelve member States then making up the European Community.
It was concluded from the survey, that the name "feta" had not become the common name of the product, and that it continued to evoke a Greek origin. The name "feta" was thus registered as a PDO to cover Feta produced in Greece. Denmark, Germany and France contested the decision, on the basis that feta cheese has been produced and legally marketed under the name "feta" since 1963 in Denmark, 1981 in the Netherlands and 1985 in Germany, for example. Greece also contests the process, since sheep and/or goats milk should be used, and certain countries use cow's milk in the process.
The ECJ concluded that the Commission had played down the situation existant in the Member States other than the state of origin. The Commission whilst conducting the survey back in 1996 did not take into account all the factors at play. In order to decide whether a name has become generic or not, the situation existing in the Member State in which the name originates and in areas of consumption, together with the relevant national or Community legislation, must all be taken into account. Particularly the Commission should have taken into account the existence of similar products legally on the market. The procedure the Commission followed to determine whether the name "feta" had become generic or not was found void, hence the ECJ anulled the regulation which registered "feta" as a protected designation of origin for "feta" cheese produced in Greece.
The World Trade Organization & The Feta Cheese Legal Struggle:
The World Trade Organization has a similar take on intellectual property as the ECJ with regard to naming a product after its geographic origin. The WTO under the Treaty on Trade Related Intellectual Property Rights (TRIPS) agreement states that "the use of a place to describe a product in this way -a "geographical indication"- usually identifies both its geographical origin and its characteristics". It also states that exceptions are allowed if the name is a trademark or if it has become the generic name of the product. The ECJ reversed its decision based on the fact that 'feta' had become the generic name of that particular type of cheese. Both the WTO and the European Union (EU), who abides by the rules and rulings of the ECJ, have the same position on the issue. Greece could in theory pursue this case within the realm of the WTO once its legal possibilities within the EU are exhausted. This would allow for the case to gain more international exposure and both sides would have to resubmit their positions leaving room for an interpretation which would favor Greece once again.
Whether one views this case from the WTO or the EU perspective on intellectual property with regards to geographical origin of products or foodstuffs it makes no major difference. The TRIPS clause defines geographical origin as a good originating in the territory of a member, or a region or lacality in that territory, where a given quality, reputation, or other characteristic of the good is essentially attributable to its geographical origin. This definition is very similar to that put forth by the European Court of Justice.
The WTO's enforcement of intellectual property rights seeks to protect the creator of a particular good by allowing him to be the only one that can produce that particular type of good. In doing so it also protects the consumer by guaranteeing the process and ingredients of the product he/she is buying. The EU with its appointment of products as PDO seeks to achieve the same goal within its economic community. Many products enjoy such protection, and in many cases it serves as an indication of quality. If 'feta' cheese were categorized as a PDO the consumer would also be protected from similar products which offer in certain cases a very different taste to the traditional Greek taste of 'feta'. Such is the case with cheese labeled as 'feta' in the US which is made from cow's milk. This can only resemble the original product and in no way follows the conditions put forth by the Greek government's parameters for the labeling of a cheese as 'feta'.
This allows for a tremendous discrepancy of quality and content of the same product. When one buys 'blue cheese' he expects to get a taste similar to that of 'Roquefort' cheese produced in France, but is aware that he is not getting the true traditional product but rather an imitation. With 'feta' cheese it is the same just that when the consumer buys the product he is not aware that he is purchasing a different version of the traditional 'feta' cheese. The traditional production and taste of the product is not promoted so both the producer and consumer loose, it is a no win situation.
A point should be made with regard to the categorization of this particular case. It could be categorized in the 'water, food and drink' category or in the 'intellectual property' category. Because of its lack of clarity finding related cases was complicated. In total I found four cases which are directly related to mine, these are: basmati, cassis, chocolat, and pisco.
Of these four relevant cases only two are in western Europe, cassis and chocolat, and neither of them are categorized under intellectual property. Three of the cases are categorized under the environmental problem of 'general habitat loss' (chocolat, basmati, and pisco), the remaining case, cassis, is categorized under 'indigenous rights'. The only two cases categorized under 'intellectual property' as the scope are basmati and pisco.
#1)Western Europe cases in the TED Database:
In the Cassis case both France and Germany battle over the level of alcohol in the cassis alcoholic drink. The battle is a matter of national minimum standards in Germany and how they clash against French minimum alcohol standards. These two countries are now battling Greece about 'FETA' cheese, which is as Greek as the Acropolis is. The legal framework of the EU allows countries with such discrepancies to sort it out in the ECJ.
This case clearly falls within the context of existing cases because of its legal struggle within the context of the European Union. Two cases are directly relevant, and the others are clear examples of how EU regulations have come to cover every aspect of Europe, whether one agrees with it or not.
#2) Intellectual Property cases in the TED Database:
In the basmati case study the United States and India battle over the name of a particular form of rice, while in the pisco case study Chile and Peru battle over the name of an alcoholic beverage. In this case Greece battles Denmark, Germany, adn France over the name of a particular kind of cheese. These cases are directly related to each other even though they range from four distinct and far from each other continents.
Feta is as Greek as pisco liquor is Peruvian and basmati rice is Indian. These three products elaboration dates back thousands of years so they have become national symbols. Just like in Greece, where a meal is not complete until feta cheese is at the table, in Peru a meal is not complete unless there is pisco sour on the table.
Basmati rice is a slender, aromatic long grain rice with a nutty taste delicate texture that grows best in the valleys of Punjab in the Himalayan mountains (Adewumi). Only Peru has the soil, the climate, and the tradition in making pisco that gives [this] drink a special taste, and which allows [it] to be called pisco (Oakes). The above descriptions emphasize the importance of a products geographical origin, Greece is battling to achieve such recognition for its 'feta' cheese.
The name of a product is fundamental to its economic success, if this were not so these cases and several other similar cases would not be occurring. What should be pointed out is that in both the basmati case and the feta case, there is more at stake than just a name. Both India and Greece are economic midgets compared to the countries they are battling. The economy of these two countries will feel the slap if the product can originate from a different source other than the original countries. If this were not true why did France fight till the end to protect the name 'champagne' and 'cognac'? France is a country which its economy does not rely on these exports, India has at stake 10 percent of the total basmati exports. It is also a matter of protecting the products image, no matter how well other countries try to imitate the product, the conditions can never be fully replicated. The issue of these two case studies is identical to mine, which offers the reader a perspective with regards to the many legal battles like these that occur in all corners of the world.
|Hyper-links to Related Cases|
|Basmati Rice||Pisco Liquer|
|Japanese Rice||Korean Rice|
The European Court of Justice reached a decision on March 16th of 1999, to cancel the registration of the name "FETA" as a protected designation of origin. The Greek state is expected to appeal this decision.
a. Geographic Domain: Europe
b. Geographic Site: Western Europe
c. Geographic Impact: Greece; 'Feta' is no longer considered a PDO (Protected Designation of Origin)
Greece has mild, wet winters and hot dry summers. Its terrain is mostly mountains with ranges extending into sea as peninsulas or chains of islands.
Sheep & Goats-The essence of feta:
When the Greek government set the paramaters which have to be met in order to be able to label a cheese as feta, it clearly stated that it had to be produced from sheep's milk. A combination of sheep and goats milk may also be used in the process as long as the goat's milk does not constitute more than 30% of the milk used. This clear cut specification allows the consumer to destinguish feta from other cheese and get a specialized product, but since feta is not a PDO one can buy feta produced with partially skimmed cow's milk. Using cow's milk may produce something similar to feta cheese but it is clearly not feta cheese and has a different taste altogether. The sheep or goat's milk used in the production of feta must be obtained from animals that live and graze in the following predetermined areas: Macedonia, Thrace, Thessalia, Epiros, Sterea Hellas, Peloponese, and the island of Lesvos. All these areas are in Greece, so any other milk used, even if sheep or goats milk, that does not come from these areas does not qualify under the terms set forth by the Greek government so it can not be called feta. Greece has over 2,500 native plants and shrubs which are consumed by its sheep and goats. The different plants and shrubs consumed by the animals while grazing in the predetermined areas, allows for the milk they produce to acquire a variety of flavour and aromas and are embodied in the Greek feta cheese only.
|Sheep Milk 1996
|Goat Milk 1996
|Sheep Milk 1997
|Goat Milk 1997
Feta in essence is sheep milk cheese. The name comes from the Italian word 'feta' which stands for 'slice'. The cheese was named that way because that was the way it was cut after elaboration and sold in the market. The graph above highlights the fact that Greece is one of the largest producers of sheep’s milk, essential to the elaboration of feta. The United States, Germany and Denmark do not produce sheep’s milk. This technically speaking would not allow them to produce feta cheese, since it is supposed to be made from sheep’s milk. France is the only country that produces sheep’s milk and if compared to the quantity produced in Greece the production levels are quite low.
Greece in 1997 produced 650,000 metric tons of sheep’s milk, while France only produced 220,000 metric tons. Greece even produces more goats’ milk than France, a country that is renowned for its goat cheese. In 1997 Greece produced 460,000 metric tons of goats milk, while France produced 430,000. The difference is not large, but it further highlights Greece's competitive advantage in producing feta, which is made from sheep’s or sheep and goat's milk.
Animals and animal production in Greece constitutes about 30 percent of the total value of the country's agricultural output. Sheep and goats are the largest components of Greece’s animal population amounting to an estimated total of about 14 million heads. The meat and milk of sheep and goats provides 6.2 and 6.6 percent, respectively, of the agricultural total. The country’s very limited export of animals’ products is limited mainly to cheese, whose export value in 1997 was of US$ 80 million.
Protected Designation of Origin (PDO): Geographical indication or name of a product either agricultural or foodstuffs which are protected by European Union law #1208.
a. Directly Related to Product: Yes, Feta cheese
b. Indirectly Related to Product: No
c. Not Related to Product: No
d. Related to Process: Yes, according to the Greek government 'feta' cheese is a salted white cheese traditionally produced in Greece from sheep's milk or a mixture of sheep and goat's milk.
|Value US$ 1996
|Volume MT 1996
|Value US$ 1997
|Volume MT 1997
Greece is not an economic powerhouse. This table clearly shows how Greece lags behind the countries it is battling against in the 'feta' case. Greece cheese exports are hindered by not having the sole right to label a particular type of cheese as 'feta'. It could also be interpreted from the graph how countries which control the market have a stronger say on the rules and regulations. Greece in 1997 produced 18,590,000 metric tons of cheese for export, while France produced 471,489,000 metric tons. There are no grounds for comparison with such discrepancy between the numbers. Quantitatively Greece is overwhelmed, but qualitatively Greece is still the best producer of "Feta" cheese.
|Value US$ 1996
|Volume MT 1996
|Value US$ 1997
|Volume MT 1997
This table more than anything else highlights the Greek's people fascination with cheese. Greece is currently the 10th largest importer of cheese in the world, this says allot for a population of only 10 million. As stated earlier the Greek diet revolves around cheese, thus making it the largest consumer of cheese per capita in the European Union with 23 kilos per year. France, with a population of approximately 60 million, is a close second with 22 kilos of cheese per capita a year.
The lack of substitutes is the main problem in this case. The Greek government argues that the 'feta' produced outside Greece is an imitation which is produced wrongly. Feta cheese according to the Greek government has to be produced from sheep's or a mixture of sheep and goat's milk, originating from animals that live and graze in predetermined areas, all of which are in Greece. Countries which are currently producing feta are utilizing cow's milk in its production, this creates a cheese similar to feta, but it is definitely not 'feta'. Since the cheese technically does not resemble feta, it should not be labeled as such. Consumers have become accustomed to the name 'feta' so coming up with an alternate name will be a marketing blow for the other countries. If the protected designation of origin rules and regulations are to be applied fairly throughout all products, 'feta' should be one of the products under that category.
Kostas, Lavdas. The Europeanization of Greece MacMillan Press, London, 1997
Lee, James. Trade, Environment and Culture: Globalization in Human History (Manuscript of September 1999)
Legg, Keith & Roberts, John, eds.Modern Greece: A Civilization on the Periphery, Westview Press, Colorado 1997.
Mamalakis, Elias. Greek Cheese: Tastes and Recipes Troxalia Press, Athens, Greece 1999.
Yannis, Stivachtis.The Enlargement of International Society MacMillan Press, London, 1998
Adewumi, Jolayemi-Basmati Rice
CIA World Fact Book
European Court of Justice
Oakes, Pamela-Pisco Liquor
The WTO Agreements in the Uruguay Round
Mamalakis, Elias. Greek Cheese: Tastes and Recipes Troxalia Press, Athens, Greece 1999.
Author's personal photos