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Trade mark rights stop at the border. A UK registration protects you in the UK and nowhere else – which surprises founders the first time a distributor, marketplace seller or copycat appears abroad. The good news: protecting a brand internationally is more systematic, and often cheaper, than people expect.
Your two routes: Madrid or direct
There is no single worldwide trade mark, but the Madrid Protocol comes close to one-stop filing. Using your UK application or registration as a base, you file one international application through the UKIPO, designate the countries you want, and pay one set of fees. Each designated country then examines the mark under its own law, exactly as if you had filed there directly.
Direct national filing means instructing attorneys country by country. It costs more in management overhead but is the right call when a target country is not in Madrid (a handful of markets), when the application needs local tailoring, or when you want independent registrations not tied to your UK base for the first five years.
Where most UK businesses file first
- European Union. One EUIPO application covers all 27 member states. Since Brexit the UK registration no longer extends there, so the EU is usually the first addition for any business selling into Europe. See our EU trade mark registration service.
- United States. The USPTO examines on use as well as conflict, and foreign applicants must appoint a US-licensed attorney. Getting the filing basis right (use vs intent-to-use) avoids the most common refusals. Our US trade mark service handles this end to end.
- China. First-to-file rules and active bad-faith filing make China a “file early or lose it” market – including the Chinese-character version of your brand. We run a dedicated China filing service.
- Canada, Australia, Japan, UAE. Straightforward Madrid designations in most cases.
Use your priority window
Under the Paris Convention you have six months from your first filing to file abroad while claiming the original filing date. Anyone who files in between – a squatter watching UK filings, say – loses to you. Miss the window and the race restarts in each country. This is the strongest argument for deciding your international strategy at the same time as your UK filing, not after it.
What it costs
Madrid fees stack by country: a base fee plus a per-designation fee, with some countries charging individual fees. A three-country designation typically lands in the low thousands all-in – meaningful money, but a fraction of the cost of a dispute in even one market. Direct filings vary widely by country and attorney.
Five rules for filing abroad
- File where you sell, where you manufacture, and where copycats file. The third category catches people out – China especially.
- Check the mark translates safely. Meaning, pronunciation and script versions all matter.
- Use Madrid when it fits. One renewal, one recordal of changes, central management.
- Watch your dependencies. Madrid designations hang off your base registration for five years – if the UK mark falls, they fall.
- Put a watch in place. New filings abroad need monitoring just like UK ones; our watch service covers overseas registries.
Getting started
The right sequence for most businesses: file the UK first, decide target markets within the six-month priority window, then extend by Madrid or direct filing. Our international trade mark service maps your markets to the cheapest compliant route and manages the filings, deadlines and renewals in one place.
Frequently asked questions
Is there such a thing as a worldwide trade mark?
No single registration covers the world. The Madrid Protocol lets you file one international application designating over 130 member countries, each of which then examines the mark nationally.
How long do I have to file abroad after my UK application?
Six months to claim your UK priority date under the Paris Convention. After that you can still file, but intervening third-party filings take priority over you.
Does my EU trade mark still cover the UK after Brexit?
No. EU registrations stopped covering the UK at the end of the Brexit transition; comparable UK registrations were cloned automatically, but new protection needs separate UK and EU filings.
Which countries should I prioritise?
Where you sell now, where you will sell in two years, where you manufacture, and first-to-file jurisdictions with active squatting – China above all.
