The representative of the European Communities explained why geographical indications for wines and spirits benefited from both Articles 22 and 23. Article 23 prohibited the use of a geographical indication of a specific wine on another wine. For example, it could prohibit the use of an Australian geographical indication, "Barossa", on a wine from the EC. It could also forbid the use of a geographical indication for spirits like "Scotch whisky" for a whisky from Argentina. Nothing, however, in Article 23 prevented the use of a geographical indication for spirits, "Cognac", on a wine or the use of a geographical indication of a wine on a spirit or, even less, the use of a geographical indication for a wine like "Champagne" on a perfume or on a service. That was why, in a real case that had occurred in France on the basis of Article 22 - which was the default protection for all products including wines and spirits - the French court had found that Article 22 and the test of consumer deception prohibited the use of the name "Champagne" on a perfume.
