Fake bottles of Lafite-Rothschild grab headlines, but according to Bordeaux's wine trade council, only a small portion of wine fraud involves counterfeit labels of real châteaus. A much bigger worry for Bordeaux is wine labeled with fictitious châteaus using Bordeaux AOCs. "The main issue is the misuse of the name 'Bordeaux,'" said Allan Sichel, a négociant and member of the Conseil Interprofessionnel du Vin de Bordeaux (CIVB), during a recent meeting at the French Consulate in Hong Kong.

But Bordeaux has little recourse against these Chinese-made Bordeauxs, because Bordeaux is not a protected geographic indication (GI) in China. The Bordelais are working to change that.

"Graves Pomerol," "Château Margot," "Chatreal Latour, Bordeaux"—all are fakes on the Chinese market that are easy to spot if you know Bordeaux, but not so easy if you're a Mandarin-speaking customs inspector with little knowledge of wine.

Normally, trade agreements tackle this issue, but the European Union does not have an agreement with China that protects appellation names, and Bordeaux is losing business to Chinese-made fakes. China bought 42 million bottles of Bordeaux last year. The CIVB believes Chinese consumers could be buying more if every time they reached for Bordeaux they were getting the real thing.

But until China recognizes Bordeaux as a protected GI, there isn't a lot of legal recourse. "The protection of geographical indications is notoriously insufficient," said Georges Haushalter, CIVB president. Champagne and Cognac already have GI protection in China. "As China is our No. 1 export market, we launched a specific action with Chinese authorities."

Last March, the CIVB took a member of the EU Trade Commission on a fact-finding mission to China, meeting with Chinese officials, and highlighted the issue for both sides. China signed a cooperation agreement with the CIVB, and sent their officials and investigators to wine school. "This way they know what to look for," said Christophe Chateau of the CIVB. "They recognize the appellations and realize that you can't make Champagne in Bordeaux."

The trained inspectors will have an app—SmartBordeaux—on their handhelds, so they can quickly determine the authenticity of a label. The plan is that they will spot the fake Bordeaux, and pass on their findings to the authorities.

"But these actions won't have a dissuasive effect if the appellation Bordeaux is not recognized as a geographical indication on Chinese soil," said Haushalter. So last spring, Bordeaux increased pressure on the Chinese to recognize Bordeaux as a GI. But the Chinese wanted something in return. "They said, we'll recognize one of your appellations if you recognize one of ours," said Chateau. "They have about 20, we have 1,000. We said, sure, sure, but this is urgent." While CIVB officials admit that they can't completely stop fraud in China, they hope to win GI protection by 2012.

In the meantime, the CIVB is asking winegrowers to protect themselves by copyrighting their brand in China. Unfortunately, it costs between $800 and $1,100—too much for the smaller producers to pay when they are just starting to ship to China. Usually, once business picks up, they get out the paperwork.

"But then it's too late," said Chateau. "If you want to change your distributor, and your distributor has copyrighted your wine brand, which they do, then he owns it in China not you. I tell them: It doesn't matter if your family has owned the château for 150 years. Whoever copyrights the brand first, owns it."