Dr. Ioannis Kaimakamis
Greek Feta is the largest PDO cheese in the EU by volume, yet the only major one without an Article 150 supply-management regime, and the 2024-26 disease crisis has turned that gap from a technical curiosity into a strategic vulnerability. While France (Comté, Beaufort, Reblochon, Morbier, Abondance) and Italy (Parmigiano Reggiano, Grana Padano, Pecorino Romano, Asiago) have used Article 150 of Regulation (EU) 1308/2013 continuously to defend farmgate-milk premia of 30–80% and to discipline volume against demand, Greece has only just acquired the institutional vehicle (EDOF, recognised in 2021) and has never submitted a dossier. With peste des petits ruminants confirmed in Thessaly in July 2024, sheeppox/goat pox spreading from August 2024, foot-and-mouth disease in Lesvos in March 2026, and roughly 487,000 small ruminants culled by April 2026 (~5% of the national flock), the raw-milk pool underpinning Feta’s €785m-€900m export franchise is contracting structurally. This report sets out the legal mechanics of Article 150, the lessons of two decades of French and Italian practice, the actual state of Greek institutional architecture, the dynamics of the current shock, and a concrete five-year activation pathway anchored on an Article 222 emergency bridge.
Article 150, the legal architecture, decoded
Article 150 of Regulation (EU) No 1308/2013 (single CMO Regulation), inserted by Regulation (EU) 261/2012 (the “Milk Package”) and amended by Regulations (EU) 2017/2393 and (EU) 2021/2117, sits in Part II, Title II, Chapter II, Section 3. Its purpose, set out in Recital 129, is to allow Member States at the request of a recognised producer organisation (Art. 152), interbranch organisation (Art. 157) or PDO/PGI producer group (formerly Reg. 1151/2012, now Reg. 2024/1143) to make rules regulating the supply of PDO/PGI cheese binding on all operators in the geographical area, in derogation from Article 101(1) TFEU.
The 2/3 + 2/3 representativeness threshold is the gatekeeper. Article 150(2) requires a prior agreement, valid for at least one year, between at least two-thirds of milk producers (or their representatives) representing two-thirds of the raw milk used for that cheese and at least two-thirds of the cheesemakers representing two-thirds of cheese production in the geographic area. Both gates are cumulative; failing either kills the dossier. The Commission and most national authorities read the milk-side threshold strictly; historical milk-flow registries (in Greece, ARTEMIS) serve as the audit basis.
What binding rules can and cannot contain. Article 150(3) authorises volume regulation calibrated to demand, quality grading, the timing of market placement, allocation rules for new entrants, and seasonal smoothing. It explicitly forbids price-fixing in any form (including indicative, recommended or pivot prices), market-sharing, supplier or customer allocation, discrimination, restrictions on transactions after first marketing, anything that damages trade in non-PDO products, and rules that “render unavailable an excessive proportion of supply.” Rules are time-limited to three years, renewable, and must be published in an official Member-State publication.
Procedure. The recognised IBO/PO/GI group submits a request to the competent Member-State authority (in France, INAO + Ministry of Agriculture; in Italy, MASAF in conjunction with the Consorzio); the Member State adopts a binding national act (a French arrêté interministériel or an Italian ministerial decree); the Member State notifies the Commission before implementation under Article 150(5). The Commission has effectively a four-month standstill window during which it may, by implementing an act adopted without comitology under Article 150(6), require repeal where the rule “precludes or distorts competition over a substantial part of the internal market,” “compromises free trade,” or “jeopardises the objectives of Article 39 TFEU.” No Article 150 cheese notification has ever been formally blocked; some have been technically amended after Commission scrutiny. Article 150(7) empowers further delegated acts, but no general delegated act dedicated to Article 150 has been adopted (Reg. 2016/1166 concerns sugar beet and is unrelated).
Article 101 TFEU interaction. Article 150 is anchored in Article 42 TFEU, which subordinates competition rules to CAP objectives, and in Article 206 CMO (which makes EU competition law applicable to agriculture unless this Regulation provides otherwise). The doctrinal frame is the Grand Chamber’s Endives judgment (Case C-671/15, 14 November 2017): conduct that is strictly necessary and proportionate to the missions assigned by the CMO can escape Article 101(1), but collective price-fixing remains prohibited even within an agricultural derogation. The 2019 Spanish raw-milk cartel (CNMC S/0425/12; Audiencia Nacional, 21 February 2024; Madrid Commercial Court 14, 16 October 2025, quantifying a 9.4% raw-milk undercharge) confirms the limits: dairy processors colluding on purchase prices outside a recognised IBO/PO frame remain fully exposed to Article 101.
The new GI Regulation (EU) 2024/1143, applicable from 13 May 2024, with key provisions from 1 January 2025, strengthens the producer group’s hand without displacing Article 150. Its Article 32 lists the standard functions of any GI producer group; its Article 33 introduces the figure of the “recognised producer group,” which may exercise rights erga omnes, adopt rules more stringent than the product specification, lay down binding sustainability undertakings under Article 7 (extended by Member-State act), and undertake value-chain governance including monitoring of production capacity in coordination with sustainability and quality goals. Recital 33 explicitly endorses fair value distribution. Article 33 is essentially the upstream/quality twin of Article 150: a single recognised producer group can now combine binding sustainability rules under Reg. 2024/1143 with binding volume rules under Article 150 CMO. For Feta, this is decisive; it provides a coherent platform to defend the grazing/transhumance core of the PDO specification while regulating supply.
The French and Italian playbook what works, and why
Two decades of practice have produced a remarkably stable model. Across the ten leading cheese-PDO supply-management regimes documented below, the median outcome is a 20-40% farmgate-milk premium, retail-price multiples of 1.5–3× over conventional benchmarks, and stable or rising volumes within a planned trajectory.
| PDO | First Article 150 plan | Volume (t/year) | Producers / dairies | Milk-price premium | Notes |
|---|---|---|---|---|---|
| Comté (FR) | 2013-14 (formalised pre-existing rules) | ~65,000 | 2,400 farms / 153 fruitières / 14 affineurs | +30-40% | “Plaque verte” since 1990s; +1.6-2%/yr cap |
| Beaufort (FR) | 2014-15 | ~5,300 | ~400 farms / 7 coops + alpages | +60-80% | 5,000 L/cow ceiling France MontagnesFromage-beaufort |
| Reblochon (FR) | Arrêté 22-4-2014 Agra | ~16,000 | 620 farms Taste France / ~30 dairies | +20-30% | Q2 cap 22% of référence basse Réussir |
| Morbier (FR) | 2017 (seasonal); 2018, 2020, 2022 | ~12,000 | shared with Comté | Modest | Seasonal Q1 cap, 15× over-quota fee |
| Abondance (FR) | 2019 (BO 4-4-2019) | ~2,600 | ~210 farms | +40-50% | 8,000 kg/cow yield ceiling |
| Parmigiano Reggiano (IT) | 2014-16 plan | ~163,000 / 4m wheels | 2,400 farms / 330 dairies | +25-40% | Consorzio since 1934; Emilia Delizia QLPR/PEC system |
| Grana Padano (IT) | 2014-16; current 2025–27 (DM 10-4-2025) | ~5.6m wheels Ruminantia(~225,000) | 3,576 farms Ruminantia / 130 dairies | +5-15% | “Expansive” 3%/yr growth model Ruminantia |
| Pecorino Romano (IT) | 2010-12 plan; current 2023–25/26 | 30,000-35,000 | ~9,000 sheep farms / ~40 caseifici | Volatile, plan stabilises ~+30% | The closest sheep-milk analogue to Feta |
| Asiago (IT) | 2014- ; current 2024–26 | ~21,000 | 1,200 farms / 38 dairies | Modest | Newcomer pool 2.5-5% of PE |
| Gruyère IGP (FR) | ~2015 | ~2,500-3,000 | ~120 farms | Modest | PGI-only after Swiss PDO Institute of Culinary Education |
What made these regimes succeed? Five institutional preconditions stand out. First, deep-rooted single-IBO governance: the Consorzio del Formaggio Parmigiano-Reggiano (1934), the CIGC for Comté (1963), the Grana Padano Consorzio (1954), institutions with multi-decadal credibility before Article 150 ever existed. Second, a dense cooperative milk-aggregation tier: Comté’s 153 fruitières mediate between 2,400 farms and 14 affineurs; Italian latterie sociali historically produced 80%+ of Parmigiano. Third, specifications that already function as physical caps, breed restrictions (Montbéliarde/Simmental for Comté; Sarda for Pecorino Romano), forage-area rules (4,600 L milk/ha for Comté), per-cow yield ceilings (5,000 L for Beaufort, 8,000 kg for Abondance), 25-km milk-collection radius. Fourth, a single, visible enforcement device: Comté’s plaque verte (casein label per wheel), Reblochon’s red/green plaques, Parmigiano’s QLPR, Pecorino’s quote per caseificio. Fifth, vertical alignment of milk producers and processors that makes the 2/3+2/3 supermajority feasible.
The political-economy battle is real. Pro-supply-management coalitions are typically small/medium cooperatives, mountain producers, INAO/MASAF and DG AGRI quality units; opponents are large private processors preferring expansion (notably some Grana Padano industrial dairies and private Pecorino Romano caseifici), competing PDOs in shared milk basins (Morbier vs Comté; Asiago vs Grana vs Montasio), and DG COMP. The Italian Antitrust Authority’s 1996 Decision 4352 had ruled Grana volume coordination anti-competitive outside the CAP framework; Article 126e/150 was the explicit legislative response. The Commission’s role during the four-month standstill has been to police proportionality and newcomer access, not to block.
Pecorino Romano is the most instructive analogue for Feta. Both are sheep-milk PDOs, both face short-run inelastic seasonal supply, and both are export-dependent (Pecorino sends 50-60% abroad, with ~40-50% of exports going to a single market, the United States, making it Italy’s most US-dependent PDO). The Sardinian shepherds’ “milk strike” of February 2019, when farmgate price collapsed to €0.60/L, illustrates that a binding Article 150 plan is necessary but not sufficient without parallel private-storage aid, crisis withdrawal mechanisms, and export-market diversification. Pecorino’s structural asymmetry, a few large processors confronting ~9,000 shepherds, mirrors Greek conditions almost exactly.
Greek institutional architecture. Finally functional, not yet weight-bearing
EDOF (Εθνική Διεπαγγελματική Οργάνωση Τυριού “ΦΕΤΑΣ”), the National Interbranch Organisation for Feta Cheese, was constituted on 13 January 2020 under Minister Voridis after a seven-year stalemate, signed on 6 February 2020, and formally recognised by the Ministry of Agriculture in late 2021 under Greek Law 4647/2019 (transposing CMO Articles 157–158) and the Ministerial Decision of 24 December 2019. Its 9-seat board allocates 4 seats to SEVGAP (industrial processors), 3 to producer organisations (SEK, PEK, Federation of Thessaly Stockbreeders), and 2 to cheesemakers (ODIPPAF ~162 firms; Thessaly Cheesemakers’ Association ~48 firms). Its current President (elected at the GA of 23 March 2026) is Mihalis Sarantis, CEO of Hellenic Dairies, succeeding Ioannis Vitalis (Dodoni). Sarantis has publicly stated that EDOF represents “more than 65%” of Feta production, sufficient for Article 164 erga omnes extension, but not yet demonstrably the 2/3 + 2/3 required by Article 150(2). No public independent audit confirms producer-side representativeness, and the 2024 revocation of EDOK (meat) recognition over representativeness deficiencies sets a cautionary precedent
SEVGAP, Σύνδεσμος Ελληνικών Βιομηχανιών Γαλακτοκομικών Προϊόντων (Association of Greek Dairy Industries) is the dominant processor coalition. Its membership encompasses all major industrial and cooperative-origin Feta processors: Hellenic Dairies (Olympus/Tyras), Dodoni (a 2025 100%-owned subsidiary of Hellenic Dairies after the HCC’s August 2025 Decision 894/2025), Mevgal, Kolios, Roussas, Kri-Kri, Vivartia/Optima, Trikki, Greek Family Farm (25% Hochland), and many regional dairies. SEVGAP holds 4 of 9 EDOF board seats and represents an estimated >70% of Feta volume
ELGO-DIMITRA is the single competent control body for Feta PDO under Article 36 of Reg. 1151/2012 (now Reg. 2024/1143). It maintains the iagro register (under Law 5136/2024), runs the ARTEMIS milk-balance system (KYA 838/51008/2019, FEK 964 B’/21-03-2019) which captures all sheep, goat, cow and buffalo milk deliveries by NUTS-3, executes EU-funded Feta promotion (the “Feta PDO Let’s Get Real!” campaign), and conducts physico-chemical authenticity controls (18S-rDNA, protein fingerprinting). ARTEMIS is the data backbone that any future Article 150 dossier would rely on for representativeness audit. Greece transposed Article 148 of the CMO on mandatory written contracts through the same KYA, a critical legal infrastructure already in place.
Competitive structure. ELGO 2024 data: 38,668 sheep-milk producers + 12,625 goat-milk producers ≈ 46,000 active dairy farms supplying the Feta zone, down ~30% from 2020. The Greek sheep population stood at 7.77 million in December 2024 (4th in the EU). Average flock size in NW Greece field studies is 174–189 milked ewes; smallholders of 100-200 head dominate, with flocks above 500 ewes representing under 10% of holdings but a disproportionate share of milk. Vertical integration is limited. Dodoni works with >4,500 contracted farmers in Epirus; Epirus owns farms in Epirus and C. Greece, but the overwhelming volume relationship remains farmer → private dairy via short-term forward contracts, mediated by cooperatives or directly. The structural asymmetry, ~46,000 fragmented farms vs ~200 PDO-certified processors, is the defining feature.
Total Feta production in 2025 was approximately 140,000 tonnes, of which ~105,000 tonnes were exported (8.7% YoY growth) for an export value of €835m (rising from €138.8m in 2007, a +502% multi-decade trajectory). Direct ELSTAT export data show €736m (2023) and €785m (2024); the often-cited “€1bn” figure incorporates indirect value-chain effects. Exports account for 65-70% of output, concentrated in Germany, the UK, Italy, France, and the US.
Pricing. Sheep milk averaged €1.55/kg in 2023 (record), €1.44 in 2024, €1.38 in Q1 2025 and rebounded to €1.49 in January 2026 and €1.51 in February 2026 (+9% YoY); goat milk fell from €0.97 (2023) to €0.88 (Q1 2025); cow milk traded at €0.52-0.54. The Feta-zone (sheep/goat) premium over cow milk is therefore 2.5–3×. The production cost in 2023–24 was €1.64/kg, above the farmgate price for most of 2024. By late 2025/early 2026, sheep-milk prices were quoted at €1.65/kg or higher, reflecting the supply shock. Contracts are predominantly annual (Oct–Sep), with >85% of volume contracted ex ante because of severe seasonality (~35% of annual sheep milk delivered in Q1, ~10% in Q3).
The 2024-26 disease shock quantified
The triple animal-health crisis is structural, not transient. PPR was confirmed in Thessaly in July 2024, the first PPR outbreak in the EU since 2018. Sheep pox and goat pox (SPGP) emerged in August 2024 and then spread aggressively throughout 2025. Foot-and-mouth disease (FMD) was confirmed in Lesvos on 16 March 2026 (SAT1 strain, with secondary Lesvos farms 22–23 March; ~700 sheep + 25 cattle culled in the second wave; 13 cases by 25 March across 140 farms in the protection zone), Greece’s first FMD outbreak in 25 years. Cumulative SPGP-attributable culls reached ~260,000 by September 2025, ~327,000 by mid-October, ~417,000 by mid-November 2025, and 486,666 confirmed culls (with ~50% dairy ewes) across 2,152 outbreaks by April 2026, approximately 5-6% of the national flock.
Geographic concentration is a Feta-zone bullseye. Outbreaks cluster in Larissa (254 outbreaks), Xanthi (245), Serres (187), Rodopi (183), all core Feta-milk catchments. Thessaly alone accounts for ~45% of Feta production and >50% of Feta exports. Regional milk-delivery declines for the October 2025–February 2026 pentamonth: Xanthi −70%, Imathia −35%, Magnesia −25%, Serres −20%, Larissa −12%; aggregate national sheep-milk deliveries down ~12%. EDOF projects a 2026 Feta production shortfall of ~20,000 t (–14%) versus the ~140,000 t baseline.
The PDO-biosecurity tension is unresolved. The Feta PDO specification (originally Commission Regulation EC No 1829/2002 confirming the PDO and its catchment area; amended specifications) requires traditional breeds, extensive grazing and seasonal transhumance as constitutive of the link to terroir, precisely the practices that disease-control veterinary measures restrict through mandatory housing, movement bans and protection zones. There is no indication that ELGO-DIMITRA, ΥΠΑΑΤ or the Commission have issued a formal temporary derogation; in practice, the inspection regime appears to be tolerating housing under emergency veterinary orders. Without a formal decision, the risk of de facto erosion of the PDO link is real and creates an opening that large processors might later exploit to seek a permanent relaxation of the specification.
Government response has been defensive, not strategic. Compensation has flowed under domestic FMD measures (the 21 March 2026 ΥΠΑΑΤ decision on unprocessable milk from Lesvos), CAP exceptional aid, and EU veterinary co-financing (Reg. 2021/690). Greece has not, as of April 2026, requested activation of Article 222 CMO emergency measures, despite this being the first-best instrument for collective supply coordination during severe market imbalance. Vaccination decisions remain politically charged: SEVGAP has publicly opposed mass vaccination on the grounds that vaccinated-area embargoes by the US, UK, Canada and Australia would cripple Feta exports, an export-led decision that may come at the cost of slower disease eradication.
Export-market consequences are already visible. Wholesale prices have firmed; retailer reports in Germany and the UK indicate intermittent availability pressure on private-label Feta. The structural risk is that European hard discounters substitute “white cheese in brine” of Bulgarian, Danish, German or French origin, products that cannot legally use the name Feta inside the EU since Cases C-465/02 and C-466/02 (Germany & Denmark v Commission, 2005) and Case C-159/20 Commission v Denmark (14 July 2022, which extended Member-State enforcement obligations to exports to third countries). They can nevertheless occupy adjacent shelf space and capture price-sensitive volume. Ten to fifteen percentage points of mass-market shelf share lost during a multi-year supply shock would be very hard to recover, even after flocks rebuild.
Why Greece has never used Article 150 and how to change that
The five reasons Article 150 has lain dormant. First, until 2021, there was simply no recognised IBO eligible to make the request; EDOF only acquired ministerial recognition four years ago, against the Italian Consorzio’s nine decades. Second, producer fragmentation has made the 2/3 milk-side threshold genuinely difficult to meet; there is no Greek equivalent of the fruitière model. Third, the political economy of large processors versus farmers: in normal markets, processors benefit from a fragmented supplier base, and SEVGAP historically blocked supply-management proposals from PASEGES, GESASE, SEK and PEK. Fourth, administrative capacity: ΥΠΑΑΤ and ELGO had not historically developed the milk-flow audit and proportionality-justification capabilities required by an Article 150 dossier (ARTEMIS only acquired its current legal basis in 2019). Fifth, and perhaps most importantly, Greek policy attention to Feta has focused on external protection (the 2002 PDO confirmation, the 2022 Denmark judgment, CETA Feta carve-outs, anti-imitation enforcement) rather than on internal supply discipline, because in a growing market, the latter seemed unnecessary.
The current crisis flips the political-economy calculus. With farm exits accelerating and milk supply contracting structurally, processors now have a rational interest in coordinated allocation to prevent intra-industry bidding wars and to defend brand value. Farmer organisations want price floors and biosecurity protection. The two camps, for the first time, broadly align.
A realistic five-year activation pathway. Sequencing matters because the legal bridge from emergency to structural intervention runs through Article 222 first.
- Immediate (2026). Greek government to formally request Article 222 CMO derogation for sheep/goat milk, citing severe market imbalance triggered by PPR/SPGP/FMD. Article 222 disapplies Article 101 TFEU for up to 6+6 months, permitting EDOF and member processors to coordinate voluntary supply rules without competition-law liability. Six implementing acts have been adopted under Article 222 between 2014 and 2023 (COM(2024) 12 final). The precedent is clear. In parallel, the Ministry of Agriculture commissions the missing econometric and value-chain study on the application of Article 150 to Feta (a documented research gap; the closest precedents are Bouamra-Mechemache & Chaaban on French PDOs and Sckokai/Donati on Parmigiano).
- Short term (2026-27). CSP fourth amendment to activate Article 47 SPR sectoral interventions for dairy under the new option in Regulation (EU) 2021/2115. Greece currently uses sectoral interventions for olive oil, fruit and vegetables, apiculture and wine, but not for dairy. Five Member States have activated the new “other sectors” option (France: €135m; Czechia: €50m; Italy: €30m for potatoes; Latvia and others). Activation would unlock co-financing for EDOF’s operating budget, biosecurity, herd rebuilding, PDO promotion, and crisis prevention/management, directly preparing the institutional capacity Article 150 will require. Independent audit of EDOF representativeness on both sides.
- Medium term (2027-28). Submit the Article 150 dossier: volume rules indexed to a five-year historical milk-delivery reference (sourced from ARTEMIS), a “green-plate” pool reserved for new young farmers (modelled on Comté’s plaque verte), a “blue-plate” growth pool linked to demand growth voted by EDOF (modelled on Grana Padano’s “expansive” 3%/yr model), three-year duration with automatic Commission review, complemented by a quality-grading ladder (e.g. extended-maturation “Feta Selection”) modelled on Comté Premier/Extra to support per-tonne value during the supply trough.
- Structural reinforcement. Use Article 33 of Regulation (EU) 2024/1143 to make the grazing/transhumance core of the Feta specification binding through Member-State act, with associated sustainability undertakings under Article 7, explicitly framing Feta supply management as protecting extensive pasture systems with biodiversity and animal-welfare benefits, anchoring the rule in Article 210a CMO (sustainability derogation) in addition to Article 150. Eco-schemes (currently ~28% of the Greek direct-payment envelope) and AECM measures reinforce the grazing requirement; Voluntary Coupled Income Support for sheep/goats is conditionalised on biosecurity compliance.
The counterfactual is brutal. Without supply management, the most plausible 2027-30 trajectory is: continued farmgate-price volatility (€1.65/kg now; collapse risk in 2027-29 once herds rebuild without coordinated allocation); retailer substitution of 10-15 percentage points of mass-market shelf share to non-PDO white cheese; brand erosion into a specialty niche; pressure to relax the PDO grazing specification to “save” volume; partial loss of US, UK and Canadian export-market position. A 20% structural erosion of the export franchise represents a €150-200m/year direct loss; full mass-market displacement would be €400-500m/year, before accounting for rural employment effects, which Bouamra-Mechemache & Chaaban (2012) document as material multipliers in PDO regions.
Risks, sequencing and the strategic insight
Legal and competition risk is manageable but not zero. DG COMP has never blocked an Article 150 cheese notification, but it does require tight proportionality and access for newcomers. The Endives doctrine (C-671/15) imposes a strict-necessity test that would defeat any drift toward indicative pricing. Bulgarian, Danish, and German “white-cheese-in-brine” producers cannot legally challenge a rule that applies only to the Greek PDO area. US producers (KraftHeinz/Athenos and others) have no standing in EU procedures; the principal external risk is reputational and lies in the CETA carve-out architecture, not in Article 150 itself. Internal Greek political risk, SEVGAP capture of the volume allocation, is mitigated by anchoring initial shares on ARTEMIS-audited historical milk delivery, by an independently chaired EDOF dispute-resolution mechanism, and by automatic three-year Commission review.
The deepest insight is that Article 222 and Article 150 are not alternatives but a sequence. Article 222 buys 12 months of coordinated emergency action; Article 150 institutionalises the discipline for the next decade. Greece has the legal infrastructure (Law 4647/2019, KYA 838/51008/2019, ARTEMIS, ELGO-DIMITRA), the IBO (EDOF since 2021), the export franchise (~€800m+ growing) and now the political-economic alignment created by the disease crisis. What is missing is a strategic decision to use them together. The French and Italian precedents show that Article 150 does not slow growth. Comté has grown from 40,000 t (1998) to 65,000 t (2023); Grana Padano targets 7m wheels by 2030, but it disciplines growth to demand and locks in the rent that pays farmers to maintain extensive grazing systems.
The specific window is now open
The PPR/SPGP/FMD shock is reshaping the small-ruminant sector, whether or not Greece intervenes strategically. The choice is not whether the flock contracts but whether the value chain contracts with it. Without Article 150, contraction risks becoming brand erosion: prices rise, retailers substitute, the PDO specification comes under pressure for reform, and Greece loses 10-15 points of European mass-market shelf share that took 20 years of post-2002 enforcement to build. With Article 150, bridged by Article 222 and reinforced by the new powers in Regulation (EU) 2024/1143 and a CSP amendment activating Article 47 dairy sectoral interventions, Greece can convert a managed flock contraction into a higher-value, lower-volume PDO trajectory paying farmers €1.65-1.80/kg sustainably while defending the export franchise. The Italian Pecorino Romano case proves the model works for sheep-milk PDOs; the institutional architecture is now in place; the political economy aligns for the first time in a generation. The window is 2026-28. After that, structural loss of shelf space in the EU mass market would be very difficult to reverse.
The strategic question for Greek and EU policymakers is therefore not technical but political: whether to convert a defensive crisis response into the first Greek deployment of the most powerful supply-management tool in the EU agricultural toolkit, a tool that France and Italy have used to defend their cheese PDO franchises for over a decade.