describing the product in question. Measures to implement these provisions should not prejudice prior trademark rights that have been acquired in good faith; and, under certain circumstances — including long-established use — continued use of a geographical indication for wines or spirits may be allowed on a scale and nature as before. In the Doha Development Round of WTO negotiations, launched in December 2001, WTO member governments are negotiating on the creation of a 'multilateral register' of geographical indications. Some countries, including the EU, are pushing for a register with legal effect, while other countries, including the United States, are pushing for a non-binding system under which the WTO would simply be notified of the members' respective geographical indications. Some governments participating in the negotiations (especially the European Communities) wish to go further and negotiate the inclusion of GIs on products other than wines and spirits under Article 23 of TRIPS. These governments argue that extending Article 23 will increase the protection of these marks in international trade. This is a controversial proposal, however, that is opposed by other governments including the United States who question the need to extend the stronger protection of Article 23 to other products. They are concerned that Article 23 protection is greater than required, in most cases, to deliver the consumer benefit that is the fundamental objective of GIs laws. Geneva Act of the Lisbon Agreement In 2015, The Geneva Act was adopted. It entered into force early-2020 with the accession of the European Union. The Geneva Act bridges the Lisbon system of Appellations of Origin, and the TRIPS system of Geographical Indications. Differences in philosophy One reason for the conflicts that occur between European and United States governments is a difference in philosophy as to what constitutes a "genuine" product. In Europe, the prevailing theory is that of terroir: that there is a specific property of a geographical area, and that dictates a strict usage of geographical designations. Thus, anyone with sheep of the right breeds can make Roquefort cheese if they are located in the part of France where that cheese is made, but nobody outside that part of France can make a blue sheep's milk cheese and call it Roquefort, even if they completely duplicate the process described in the definition of Roquefort. By contrast, in the United States, the naming is generally considered to be a matter of intellectual property.