EU Trademark vs UK Trademark: What Is the Difference?

If you are building a brand in Europe, one of the most important questions is whether you need an EU trademark, a UK trademark, or both. Since the United Kingdom is no longer part of the European Union trademark system, these are now separate rights with separate territorial coverage. An EU trademark protects your brand across the 27 EU Member States, while a UK trademark protects it in the UK and the Isle of Man.

For businesses selling online, expanding internationally, or working with distributors in more than one market, understanding this difference can save time, money, and future rebranding costs.

What Does an EU Trademark Cover?

An EU trademark is a single registration filed with the European Union Intellectual Property Office. It gives the owner protection across all current and future EU Member States through one application. The EUIPO states that an EU trademark gives an exclusive right in all EU member states, and the registration is valid for 10 years and renewable indefinitely.

The official EUIPO filing fee is €850 for one class, €50 for the second class, and €150 for each additional class.

Big Ben, London

What Does a UK Trademark Cover?

A UK trademark is a national registration filed with the UK Intellectual Property Office. The UK government explains that registering a trade mark in the UK only protects your brand in the UK and the Isle of Man.

The current online filing fee  starts at £205 for a UK trademark application, with additional fee of £60 for each additional class.

Why the Difference Matters

Before Brexit, many businesses assumed that an EU trademark was enough to cover the UK. That is no longer the case. Since 1 January 2021, EU trademarks are no longer protected in the UK, although they still protect rights in EU member states. The UKIPO also created comparable UK trade marks for existing EUTM holders.

This means that if you want protection in both markets today, you normally need to file separately in the EU and in the UK.

Which One Should You File?

The answer depends on where your business operates.

An EU trademark is usually the better choice if you want broad coverage across the European Union and expect to sell in multiple EU countries. It is also often more efficient than filing many individual national trademarks.

A UK trademark is the right choice if your main market is the United Kingdom, or if you want to make sure your brand is protected there separately after Brexit.

Many businesses need both. For example, a company selling online in the EU and UK may file one EU trademark and one UK trademark to secure coverage in both territories.

Costs of UK Trademark Registration

The cost of registering a trademark in the UK starts from £170 for one class when applying online. Each additional class costs £50. If you need professional help with searches, drafting, or handling oppositions, additional legal fees may apply – but this often saves money in the long run by preventing costly mistakes.

Can You Use Priority Between EU and UK Filings?

Yes, in many cases you can. Under the Paris Convention, trademark applicants can usually claim priority within six months of the first filing for the same mark and the same or covered goods and services. WIPO explains that this six-month priority right applies to trademarks, and both the EUIPO and UKIPO guidance confirm the six-month priority framework for trade marks.

That means you may be able to:

  • file first in the UK and later file in the EU while keeping the earlier filing date, or
  • file first in the EU and later file in the UK within the priority period.

This can be useful when you need to secure a filing date quickly and then expand protection to the second jurisdiction soon after.

Why Professional Filing Support Helps

At MyTrademarkPartner, we regularly file UK trademark applications and EU trademark applications for businesses that need protection in both markets. Coordinating the filing strategy can help you avoid gaps in coverage, especially when timing and priority matter.

A professional review can also help with:

  • selecting the right goods and services
  • checking for earlier conflicting marks
  • preparing coordinated EU and UK filings
  • deciding whether to claim priority from an earlier application

The EUIPO also notes that it is worth searching for conflicting marks before filing, since earlier rights are a common source of challenge.

Final Thoughts

The main difference between EU and UK trademark registration is simple: they protect different territories. An EU trademark covers the European Union, while a UK trademark covers the United Kingdom and the Isle of Man. Since Brexit, businesses that want both markets usually need both filings.

If your business is expanding internationally, a coordinated filing strategy can save time and reduce risk. In many cases, filing one application first and using priority for the second jurisdiction can be a smart way to protect your brand efficiently.

Ready to Register Your Trademark?

You don’t need to overpay for legal help – and you don’t need to figure it all out alone. Just tell us where you need protection, and we’ll take care of the rest.

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