Pre-Brexit: One EU trademark covered UK. Post-Brexit: Need separate UK filing. EU trademark (€1,800) + UK trademark (£170) = double cost for same coverage. Budget accordingly.
The Automatic Cloning
EU trademarks registered before 2021: Automatically cloned to UK register (free). Post-2020 EU trademarks: No UK coverage. Must file separately. Same name, two filings, two fees.
Priority Date Preservation
File EU trademark first. Within 6 months, file UK trademark claiming EU priority date. Maintains seniority. Protects against opportunistic UK filings during gap.
The Opposition Window
EU trademark granted ≠ UK trademark guaranteed. Separate oppositions possible. UK company opposes your UK filing despite EU approval. Two jurisdictions = independent examination.
Northern Ireland Exception
Northern Ireland = EU single market for goods. EU trademark covers NI for physical products. Services? Separate UK filing required. Complex hybrid status.
Renewal Coordination
EU trademark renewal: €1,500 every 10 years. UK renewal: £200 every 10 years. Separate calendars. Miss one renewal = lose half your protection. Double admin burden.
The Budget Question
Startup targeting UK + EU: Need both trademarks (€1,970 combined). Mainland EU only? EU trademark sufficient (€1,800). UK only? UK trademark cheaper (£170). Choose markets, then file.
Domain Implications
.eu domains required EU presence post-Brexit. UK companies lost .eu eligibility unless Irish/EU subsidiary. .uk domains unaffected. Coordinate domain/trademark jurisdictions.
Trademark Lens checks UK availability separately from EU - Brexit requires dual verification for comprehensive UK + EU coverage.