EU 14 Feb 2020

How Brexit effects your EU trademarks

UPDATE 2020-02-14. We now know more about the process after Brexit. Please read the updated information: How Brexit effects your EU trademarks.


The UK left the EU on 1 February 2020 and a transition period will run until 31 December 2020. During this period all EU trademark applications and registrations will continue being in force in the UK. Based on existing EU registrations and applications on 1 January 2021, corresponding national UK registrations and applications will be created as described below. Groth & Co will take the necessary actions for our clients and associates.

On 1 January 2021, based on existing EU registrations, a corresponding national UK registration will automatically be created. The national registration will retain the goods/services, application date, any noted priority and/or seniority dates, registration date and renewal date of the EU registration. It will be allocated a new national registration number.

Groth & Co will verify UK national registrations that have been created based on the EU registrations we manage. We will take responsibility for these new registrations as we do with other registrations we handle, e g reminding when it is time for renewal. 

Based on EU applications pending on 1 January 2021, there will run a nine (9) month period when it be possible to apply for registration of a corresponding national UK trademark. The national application will retain the goods/services, the application date and any noted priority and/or seniority dates of the EU application. It will be allocated a new national application number. When it is possible to apply for national registration, consult with your attorney in any pending matters.

Upon renewal of an EU registration with a renewal date before 1 January 2021, the renewal will take place within the framework of the EU registration and on 1 January 2021 a new national UK registration is automatically created as described above. In case of renewal of an EU registration that has a renewal date from 1 January 2021, the EU registration and the new national UK registration that was created on 1 January 2021 must be renewed separately. Groth & Co will monitor and manage these renewals.

International registrations (Madrid Protocol) designating the EU
Based on an EU designation of an international registration will, as of 1 January 2021, be created either a designation of the UK within the international registration or a national UK registration or application in accordance with the above. We will monitor all developments and keep our clients informed.

Please contact if you have any questions.

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