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What does BREXIT mean for UK trademark validity in Europe and vice versa?

Written by Jan Buza

Co-founder of Trama

Since 31 December 2020, the UK and EU are separate trademark jurisdictions. An EU trademark registered after that date provides no protection in the UK, and a UK trademark provides no protection in any EU member state.

For EU trademarks that were registered or pending before 31 December 2020, the UKIPO automatically created equivalent "comparable UK trademarks" at no charge. These UK trademarks kept the original EU filing and registration dates and are treated as independent UK registrations going forward. Standard UK renewal fees apply when they come up for renewal.

Any business needing protection in both the UK and the EU now requires two separate registrations: one with the EUIPO and one with the UKIPO.

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