Why You Should Register Your Trademark in the UK Separately After Brexit

Why You Should Register Your Trademark in the UK Separately After Brexit

Many businesses believe that registering a trademark in the European Union also covers the United Kingdom. That used to be true – but not anymore.

Since Brexit, the UK has its own trademark system. If you’re planning to sell, license, or promote your brand in the UK, you need to register it directly with the UK Intellectual Property Office (UKIPO).

EU Trademark = No Longer Valid in the UK

Before Brexit, an EU trademark (EUTM) gave you protection in 28 countries, including the UK. After Brexit:

  • EUTMs no longer apply in the UK
  • The UK does not recognize new EU trademarks filed after January 01, 2021
  • You must file separately in the UK for protection there

What Happens If You Don’t Register in the UK?

If you don’t register your mark in the UK:

  • Your brand is unprotected in the British market
  • A third party could register a similar name or logo before you
  • You may face legal issues or get blocked from entering the UK market

Even if you already have a registered trademark in the EU, it will not help you in the UK unless it was registered before Brexit and converted into a UK right.

Should You Register in Both the EU and the UK?

Yes – if your business plans to expand across Europe and into the UK.

Here’s a simple rule of thumb:

➡️ If you’re doing business in Germany, France, Italy, or other EU countries → File with EUIPO

➡️ If you’re doing business in England, Scotland, Wales, or Northern Ireland → File with UKIPO

The Application Process is Different

While the process is similar, there are key differences:

EUIPO (EU Trademark) UKIPO (UK Trademark)
Covers 27 EU countries Covers only the UK
Centralized examination Separate UK examiners
Application fees in EUR Application fees in GBP
Online platform in multiple languages English only

You can apply through each system directly – or work with experts who handle both for you.

Final Tip: Don’t Wait

We’ve seen businesses lose their rights in the UK simply because they didn’t realize a separate UK trademark was needed.

Whether you’re exporting products, building a franchise, or running ads online that reach UK customers, you need protection in the UK.

Let’s make sure your brand is safeon both sides of the Channel.

📩 Contact us for help with UK and EU trademark filings today.

📧 Email: ip@anlis.vn

📞 Phone: +84 899 88 6060         Mobile/Viber/Whatsapp: +84-366 469 436

🌐 Website: https://anlis.vn/

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