Does my EUTM still cover the UK?

No. Since January 1, 2021, EUTMs do not cover the UK. If you had an EUTM before Brexit, a comparable UK trademark was automatically created. New filings require separate applications.

What is a comparable UK trademark?

It's an independent UK trademark automatically created from an EUTM that was registered or pending on December 31, 2020. It has the same filing date, priority, and seniority as the original EUTM.

Do I need to file in both the UK and EU?

Only if you need brand protection in both markets. If you only operate in one jurisdiction, a single filing may be sufficient.

Can I claim priority between UK and EU?

Yes. Both the UK and EU are Paris Convention members. You can file in one jurisdiction and claim priority in the other within 6 months.

How does the Madrid Protocol work post-Brexit?

The UK remains a member of the Madrid Protocol. You can designate the UK in an international registration through [WIPO](https://www.wipo.int/madrid/en/). You can also designate the EU separately.

What about Northern Ireland?

Northern Ireland is covered by both UK trademarks and potentially EUTMs for goods (under the Windsor Framework). This is an evolving area of law.

Is dual filing expensive?

Not significantly. A UK filing (GBP 170) plus an EUTM filing (EUR 850) costs roughly EUR 1,050 for one class — a modest investment for protection across 28 countries. ---

Post-Brexit Trademark Strategy: UK and EU Dual Filing for Complete Coverage

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