By: Mia Massimo
In September 2021, South Korea sent seven pop stars to the United Nations General Assembly—not as performers, but as official presidential envoys. The world called it a music story. International lawyers should have called it foreign policy.
Fashion has long been dismissed as a soft subject for serious legal analysis. But a number of countries have spent years building legal frameworks—through Geographical Indication (GI) law, origin-labeling requirements, and state-backed cultural investment—that turn their national fashion industries into instruments of geopolitical influence. France, Italy, and South Korea offer three distinct models.
Political scientist Joseph Nye described soft power as a country’s ability to shape the preferences of others through attraction rather than coercion—through culture, values, and the image a nation projects abroad. A “Made in France” label on a luxury bag is soft power in material form. But cultural cachet is only as durable as the law protecting it. Geographical Indications (GIs) are legal protections that tie a product’s reputation to its place of origin, preventing outsiders from free-riding on that association. Most people know GIs through food and wine: “Champagne” can only come from one place. What is less appreciated is how aggressively this same logic is now being applied to fashion.
The EU’s Expansion of GI Law into Fashion
In November 2023, the EU passed Regulation 2023/2411, extending GI protections—previously limited to food, wine, and spirits—to craft and industrial products, including textiles, leather goods, jewelry, and lace. The regulation became fully applicable on December 1, 2025.
Before this, European craft producers had no EU-wide protection for their geographic brands. A factory in Vietnam could legally market a bag as “Florentine leather.” The new regulation closes that gap, creating a harmonized system administered through the EUIPO with a dedicated registration portal and Union Register.
Italy moved early. Law No. 206 of December 2023 entered into force in January 2024, establishing a national filing process before the EU portal even opened. This matters: Italy already has 6,330 GIs in force and France has 6,098—among the highest concentrations in the world. Extending that network to cover “Florentine leather,” “Venetian lace,” or “Milanese silk” would transform those geographic reputations into enforceable legal monopolies.
France: Copyright, Labels, and Legislation as Competitive Tools
France’s legal protection of its fashion industry runs deeper than GIs. Under Article L.112-2 of the French Intellectual Property Code, original fashion designs receive automatic copyright protection from the moment of creation—with no registration required. In the United States, by contrast, garment designs must pass a “separability” test to qualify, and the overall cut, shape, and pattern of a garment remain entirely unprotectable. French designers start with a stronger hand.
The “Made in France” label adds another layer. To use it, a product must be primarily manufactured and assembled in France, with compliance enforced by French customs authorities. A bag designed in Paris but sewn in Romania cannot carry it. For houses like Chanel and Hermès, that means keeping skilled artisans on French soil—which in turn sustains the very ateliers that make the “Made in France” label mean something.
Then there is the anti-fast-fashion push. A bill introduced in early 2024 and advancing through Parliament would penalize companies like Shein and Temu through mandatory environmental labeling, advertising bans, and financial penalties. It has been openly framed as a defense of France’s domestic textile sector. The law does not say “buy French.” But its structure favors the French model—quality, craft, and longevity—over its competitors.
Italy: The Same Playbook, Different Instrument
In October 2025, the Italian Senate introduced Bill DDL S. 1690, requiring brands to display the geographic origin of manufacturing as prominently as the price tag. For Italian luxury brands, whose production is largely domestic, origin transparency is a competitive asset. For foreign fast-fashion competitors, it is an exposure.
Italy is also moving aggressively on GI registrations for its fashion regions. Once a designation like “Venetian lace” becomes GI-protected, no manufacturer outside Veneto can legally use the name, regardless of how close the product is. The geographic reputation becomes a legal barrier to entry.
This is not without tension. The EU’s GI regime has already generated friction in trade negotiations. The EU-Canada CETA agreement protected only 41 of Italy’s 291 sought GIs, and the United States has long resisted expansive GI protection as protectionism in disguise. That resistance will only grow as GI claims extend from cheese and wine into luxury textiles.
South Korea: Fashion Diplomacy Without IP Law
South Korea’s model is different. Rather than protecting a geographic brand through IP law, it has built one from scratch through state investment in culture. Since 1998, the government has deliberately funded and promoted its entertainment and creative sectors as tools of national power. The Korean Wave—Hallyu—was not an accident.
The numbers reflect the strategy. Hallyu-related exports grew from a negligible share of GDP in 2004 to $12.3 billion by 2019. South Korea climbed from 21st to 15th on the 2024 Brand Finance Global Soft Power Index. By 2023, the global Hallyu fan base had reached roughly 225 million people, up from 46 million a decade earlier.
K-fashion is embedded in that ecosystem. The coordinated aesthetics of K-pop—the styling, the visual identity, and the merchandise—are part of a deliberate national brand. When President Moon appointed BTS as official presidential envoys and brought them to the UN, he was not just leveraging celebrity. He was formalizing what South Korea had been doing for years: using cultural exports—fashion included—to punch above its diplomatic weight. Moon later said the move was more effective than hundreds of speeches from heads of state.
Where France and Italy use law to make their fashion industries exclusive, South Korea makes its culture aspirational.
Fashion Law as Foreign Policy
Fashion law scholarship has focused almost entirely on IP rights for individual brands: who owns a logo, who can register a design. The state-level dimension has gone largely unexamined. Multiple U.S. legislative efforts to extend copyright protection to garment designs died in Congress, in part because of lobbying from industries that profit from copying. That political failure has real geopolitical consequences: it leaves American designers legally weaker than their French counterparts, and it reflects a trade posture that resists the kind of geographic protection Europe has spent decades building.
The EU’s December 2025 GI expansion is the clearest recent example of fashion law as foreign policy. It deploys intellectual property law to lock in a geographic competitive advantage for European producers in a global market—with real trade law consequences for everyone else. The fact that it has attracted little attention from international law scholars is a gap worth filling.
Italy’s origin-disclosure bill, France’s fast-fashion legislation, and South Korea’s government-backed cultural machine are not separate stories. They are three versions of the same argument: that fashion is a national asset worth protecting through law, policy, and diplomacy. The runway, it turns out, is foreign policy—and the legal architecture supporting it deserves to be taken seriously.
