How to Register a Trademark Internationally: Madrid, EU and UK Routes, Fees and China Risks

How to register a trademark internationally: the three routes

To register a trademark internationally you file national applications, a regional application, an international application under the Madrid Protocol, or a mix of all three, because each registration only protects the territory of the office that grants it. The UK government's own guidance makes the point bluntly: registering a trade mark in the UK only protects your brand in the UK and the Isle of Man.

• National filings. You apply directly to each country's trade mark office, usually through a local attorney, and each application is examined and fought under that country's law and language.
• Regional filings. One application to the EU Intellectual Property Office (EUIPO) produces an EU trade mark covering all 27 member states as a single right. Smaller regional systems, such as the Benelux office for Belgium, the Netherlands and Luxembourg, work the same way.
• The Madrid System. A holder of a "basic mark" in a Madrid member files one international application, in one language and one currency (Swiss francs), through its home office and designates the members where it wants protection. Each designated office then examines the mark under its own law.

The three routes are not exclusive. Most international brands use the Madrid System for markets where it works well and file directly where local practice, translation or speed make that safer. A single date ties the plan together: under Article 4C of the Paris Convention, the priority period for trade marks is six months from the first filing, so applications filed abroad within six months of your home application can claim its filing date.

What changed in 2026: Saudi Arabia, UK fees and China's new law

Three developments in 2026 change the cost and risk of registering a trade mark abroad, and anyone budgeting a filing programme this autumn should account for all of them.

Saudi Arabia joined the Madrid System. Saudi Arabia deposited its instrument of accession on 8 July 2026 and the Protocol took effect for it on 8 October 2026. Notice 35/2026 records that Saudi Arabia has extended the time limit to notify a provisional refusal from one year to 18 months, will not divide or merge international registrations, and will charge an individual fee rather than taking a share of the standard fees. Notice 37/2026, issued on 1 September 2026, sets that fee at CHF 1,397 per class for an application or subsequent designation, CHF 1,719 per class for collective or certification marks, and CHF 1,397 per class on renewal (CHF 1,612 in the grace period). Brands already holding an international registration can now add Saudi Arabia by subsequent designation, and Gulf-focused groups may want to speak to advisers in Saudi Arabia about how the Saudi office examines foreign marks.

UK official fees rose. The UK Intellectual Property Office (UKIPO) raised its fees on 1 April 2026 by an average of 25%, the first increase for trade marks since 1998, according to the IPO's fee guidance.

China rewrote its Trademark Law. The National People's Congress Standing Committee adopted a revised Trademark Law on 26 June 2026, expanding it to 87 articles in nine chapters, with effect from 1 January 2027, as summarised by the European Commission's China IP SME Helpdesk. The changes for foreign brands are covered in the China section below.

Before you file: clearance, classes and a home base

The work that decides whether an international filing programme succeeds happens before any application is lodged: clearing the mark, defining the goods and services, and securing the home filing that everything else depends on.

1. Search the mark in every target market. Free tools give a first view: EUIPO's TMview covers the EU and many national offices, and WIPO's Global Brand Database covers international registrations and many national registers. A professional clearance search in each key market goes further, because similar marks, transliterations and unregistered rights do not always surface in a database.
2. Choose classes and wording. Trade marks are filed in classes of goods and services under the Nice Classification. Fees rise with each class, and an over-broad list can invite a bad-faith attack later (see below), so the specification should match real and planned use.
3. Secure the home application. A Madrid filing must be based on an application or registration in a member office, and the international registration depends on it for five years. A narrow or weak basic mark narrows or weakens everything built on it.
4. Diarise the six-month priority window so that direct filings abroad, and the international application, can claim the home filing date.
5. Map the markets that are not Madrid members, or where direct filing is preferable, and budget local attorneys for them from the start.

How the Madrid System works

The Madrid System is a WIPO-run filing and management system under which one international application, based on a home mark, is sent to every designated member office for examination, producing a bundle of national and regional rights recorded in a single international register.

The applicant files through its "office of origin", for a UK business the UKIPO, which certifies the application and forwards it to WIPO. WIPO checks formalities, records the international registration and notifies each designated office. Each office then has a fixed period to refuse protection: under Article 5(2) of the Madrid Protocol that is one year, extendable to 18 months by declaration, with later refusals allowed where they result from an opposition. If no refusal arrives in time, protection is granted in that territory. The registration lasts ten years and is renewed centrally, and new members can be added later by subsequent designation, which carries a WIPO basic fee of CHF 300 under the schedule of fees.

WIPO's members page describes 117 members covering 133 countries and more than 80% of global trade, and notes that protection in China does not include Hong Kong or Macao, which need separate filings and, often, separate Hong Kong advisers. The System is heavily used: WIPO's Madrid Yearly Review 2026 reports about 64,000 international applications in 2025, with UK applicants filing 3,871 (up 3.7%) and more than 943,000 international registrations in force.

The five-year dependency and the "central attack" risk

For five years from the date of the international registration, every designation stands or falls with the home mark, so if the basic application or registration is refused, withdrawn, limited or cancelled in that period, the international registration is cancelled to the same extent everywhere.

Article 6(3) of the Madrid Protocol sets the rule, and it also catches proceedings that start within the five years but finish after them. A competitor who opposes or seeks to cancel the home mark can therefore knock out protection in every designated country at once, which is why the practice is called "central attack". After five years the international registration becomes independent of the basic mark under Article 6(2).

The safety net is transformation. Under Article 9quinquies, if the international registration is cancelled because the basic mark fails, the holder can file national or regional applications in the designated territories within three months and keep the original international registration date and any priority. Those applications pay full national fees, so the net is real but costly. Our sister publication Global Law Experts makes the same point in its guide to securing international trade mark protection: the dependency is the main structural risk of the Madrid route, and it is why a robust, fully cleared home filing comes first.

Filing an EU trade mark at the EUIPO

An EU trade mark is a single right covering all 27 EU member states, filed online with the EUIPO in Alicante for a basic fee of €850 for one class, according to the EUIPO's fees page.

The second class costs €50 and each class from the third onwards €150, and the registration lasts ten years, renewable indefinitely. Standard applications are normally published 8 to 11 weeks after payment, according to the EUIPO's registration FAQ. Publication opens a three-month opposition window, and an opponent pays €320; the EUIPO's opposition page says one in five EU trade mark applications is opposed.

The EU trade mark's strength is also its weakness. One right covering 27 markets is efficient, but an earlier conflicting right in a single member state can block the whole application, and the right must be put to genuine use. Businesses whose sales are concentrated in one or two member states sometimes prefer national filings; Global Law Experts compares the two options in its guide to Benelux v EUIPO filings, where its EUIPO fee table matches the official schedule. Brands entering a particular market, such as advisers in Germany, often take local advice on prior national rights before filing. Since 1 January 2021 EU trade marks no longer protect anything in the UK; the UKIPO created comparable UK marks for existing EU registrations at that point, as explained in the government's Brexit guidance, but new brands need a separate UK filing.

Registering a UK trade mark at the UKIPO

A UK trade mark costs £205 online for one class plus £60 for each additional class (£250 for one class on paper), lasts ten years and usually registers in about three to four months if nobody objects.

The fee figures come from the UKIPO's Form TM3 page, updated for the 1 April 2026 increase. After filing, the UKIPO sends an examination report within two to three weeks, the applicant has two months to resolve any objections, and the application is then published in the trade marks journal for two months, during which anyone may oppose it, according to the government's guidance on what happens after you apply. The UKIPO also notifies owners of earlier similar marks that it finds in its search.

For UK businesses the UKIPO is also the gateway to the Madrid System. An international application filed through it carries a UKIPO handling fee of £50 per application, shown on the FS4 fee sheet, on top of the Swiss franc fees paid to WIPO. Once registered, a UK mark must be used: under section 46 of the Trade Marks Act 1994 it can be revoked if it is not put to genuine use within five years of registration. Overseas groups entering Britain can find UK advisers through the directory.

International trademark cost: official fees compared

The official cost of registering a trademark internationally is the sum of the home filing fee, the WIPO basic fee and a designation fee for every country or region chosen, before any attorney, translation or search costs; the cheapest route depends on the list of countries and classes.

Under WIPO's schedule of fees, the basic fee for an international application is CHF 653, or CHF 903 if the mark is in colour. A supplementary fee of CHF 100 per class beyond three, and a complementary fee of CHF 100 per designation, apply only to members that do not charge individual fees. Most major markets do charge them, and they are published in WIPO's table of individual fees. WIPO's Madrid fee calculator gives the authoritative figure for any combination on the day you file.

Route or designation	Official fee	Source
UK application (UKIPO, online)	£205 for one class, £60 each additional class	UKIPO Form TM3
EU trade mark (EUIPO, online)	€850 for one class, €50 second class, €150 each further class	EUIPO fees page
Madrid basic fee (WIPO)	CHF 653 (black and white) or CHF 903 (colour)	WIPO schedule of fees
Madrid designation: European Union	CHF 789 first class, CHF 48 second, CHF 144 each further class	WIPO individual fees
Madrid designation: United Kingdom	CHF 240 for one class, CHF 64 each additional class	WIPO individual fees
Madrid designation: United States	CHF 460 per class	WIPO individual fees
Madrid designation: China	CHF 220 for one class, CHF 110 each additional class	WIPO individual fees
Madrid designation: Saudi Arabia (from 8 October 2026)	CHF 1,397 per class	WIPO Notice 37/2026

A worked example shows how the numbers combine. Take a UK company with a word mark (black and white) in two classes, filing at home and then designating the EU, the United States, China and Saudi Arabia through Madrid.

Item	Calculation	Official fee
UK basic application	£205 + £60	£265
UKIPO handling fee for the international application	flat fee	£50
WIPO basic fee	black and white mark	CHF 653
European Union	CHF 789 + CHF 48	CHF 837
United States	CHF 460 x 2	CHF 920
China	CHF 220 + CHF 110	CHF 330
Saudi Arabia	CHF 1,397 x 2	CHF 2,794
Total official fees		£315 plus CHF 5,534

Two points stand out. Saudi Arabia alone accounts for more than half of the Swiss franc total, so a per-class individual fee can change the economics of a filing more than the number of countries does. And official fees are only part of the cost: responding to a provisional refusal in the United States, China or the Gulf normally requires US counsel or another local attorney, and those fees are charged in each country.

Madrid, national filings or the EUIPO: how to choose

Use the Madrid System when you want several member countries from one application and the home mark is solid; file directly where you need speed, local control or a market outside Madrid; use the EUIPO when the EU is a single market for your business.

Factor	Madrid international application	Direct national filings	EU trade mark (EUIPO)
Coverage	Any of 133 countries in Madrid members	One country per filing, including non-members	All 27 EU member states as one right
Basis	Needs a home application or registration	Stand-alone	Stand-alone
Fees	One payment in Swiss francs to WIPO	Local fees and local attorney in each country	One fee in euros
Main risk	Five-year dependency on the basic mark	Cost and admin of many separate rights	One prior right in one member state can block the whole mark
Management	Renewals and ownership changes recorded centrally	Separate renewals and recordals in each office	One renewal every ten years
Best for	Multi-country roll-outs with a stable brand	Few key markets, non-members, urgent or complex marks	Brands treating the EU as one market

In practice the decision is rarely binary. A common pattern for a UK brand is a UK filing, an EU trade mark (either direct or as a Madrid designation), and Madrid designations for other members, with direct filings where local advice says it is safer, notably in first-to-file markets with heavy squatting. The choice is worth testing with an attorney before filing, because a route chosen for cost can be expensive to unpick.

First-to-file countries and China: register before you launch

In a first-to-file country the first valid applicant owns the mark regardless of who used it first, so a brand that sells, sources or exhibits in China before registering there risks finding its own name owned by someone else.

The European Commission's China IP SME Helpdesk states that China operates a first-to-file system, that a European registration is not protected in China, and that foreign applicants without residence or a place of business there must file through a local Chinese trade mark agent. It recommends putting an IP strategy in place at least a year before doing business in China, and says examination by the China National Intellectual Property Administration (CNIPA) takes up to nine months, followed by a three-month opposition period. China can be designated through Madrid, but many brands also file directly, and file Chinese-character versions of the mark, a step Global Law Experts recommends in its guide to protecting famous foreign brands in China to block common squatting tactics.

The revised Trademark Law that takes effect on 1 January 2027 tightens the rules on both sides. According to the China IP SME Helpdesk's analysis, Article 36 shortens the opposition period from three months to two, and bad-faith filers can face a warning and a fine of up to RMB 100,000. China Daily's report on the adoption adds that applications filed without intent to use, or beyond normal business needs, will be rejected, and that a registered mark unused for three consecutive years without a legitimate reason will be revoked; it quotes the NPC's Legislative Affairs Commission on "malicious trademark applications that seriously squeeze public resources". For brand owners the practical message is to file early, watch Chinese publications closely, and keep evidence of use. Experienced China specialists can advise on the subclass system and on whether to file directly, via Madrid, or both.

Oppositions, bad-faith filings and trademark squatting

An opposition is a challenge to a pending application filed in a short window after publication, while a bad-faith or squatting claim attacks a mark that was applied for dishonestly or with no intention to use it; both are the main tools against copycat filings abroad.

Opposition windows are short and differ by office: three months after publication at the EUIPO, two months at the UKIPO, three months in China until the end of 2026 and two months from 2027. Missing one usually means a slower and costlier invalidity action later. Under Madrid, a designated office can also issue a late provisional refusal based on an opposition, and Saudi Arabia's declaration under Article 5(2) preserves that option.

Bad faith is an absolute bar in the UK: section 3(6) of the Trade Marks Act 1994 provides that a mark shall not be registered "if or to the extent that the application is made in bad faith". In SkyKick v Sky [2024] UKSC 36, decided on 13 November 2024, the Supreme Court held that the High Court had been entitled to find that some of Sky's marks were applied for in bad faith, and that the overall width of a specification of goods or services can, depending on all the circumstances, support an inference of bad faith. The lesson cuts both ways: it gives brand owners a tool against squatters who file sweeping specifications, and it warns brand owners themselves not to claim goods and services they have no intention of using. When a squatter files first, the usual sequence is evidence gathering (prior use, reputation, the squatter's other filings), then opposition or invalidation, sometimes a non-use attack, and only then negotiation over a buy-back.

Watching and enforcing your trade marks abroad

Registration is only the start: a trade mark watch flags conflicting applications in time to oppose them, and enforcement turns the registration into removed listings, seized goods and court orders.

Owners can track their own international registrations in WIPO's Madrid Monitor and run periodic searches in TMview and the Global Brand Database, but most brands with real exposure abroad pay for a professional watch across the offices that matter, with alerts timed to opposition deadlines. Shorter windows, such as China's two months from 2027, make that timing more important.

Enforcement tools differ by market. Customs recordals let border authorities intercept counterfeits; in China that means recording the mark with the General Administration of Customs, as the Global Law Experts China guide explains. Online, marketplaces act on takedown notices backed by a registration, and regulators are pressing platforms harder: the European Commission's record €550 million Digital Services Act fine on AliExpress concerned counterfeit and unsafe listings, and the English courts' ruling in Swatch v Samsung held an app store liable for third-party watch faces copying Swatch group marks. Use matters too: unused marks can be revoked after five years in the UK and three in China under its new law, so keep dated evidence of use in each market.

When you need a local trade mark attorney, and what to prepare

You need a local trade mark attorney whenever an office requires one (China does for foreign applicants without a local presence), whenever a provisional refusal or opposition arrives, and before you choose routes for a multi-country programme, because the expensive mistakes are made at the planning stage.

Specialist advice is most valuable in five situations: clearing a mark in a market where you plan to launch, deciding between Madrid and direct filings, responding to a refusal or opposition within a tight deadline, recovering a mark from a squatter, and enforcing against counterfeits or lookalikes. Before instructing anyone, prepare:

• The mark itself: the word mark, any logo, colour claims and any transliterations or translations you plan to use.
• Your list of countries in priority order, with launch dates, sourcing locations, trade fairs and online sales channels.
• The goods and services, described in plain language, separating current use from genuine plans.
• Existing filings and dates, including any home application that could support priority within six months.
• Known conflicts: similar marks, distributors or former partners who may have filed, and any marketplace listings.
• Your budget and timing, including whether any market must be secured before a specific event.

Corporate INTL's Find an Expert directory lists vetted lawyers and advisers in more than 150 jurisdictions, including intellectual property specialists and cross-border advisers who coordinate multi-country work. If you are planning filings now, use the form below to tell us the countries you are filing in and we will put you in touch with a member.

Related Corporate INTL coverage

Trade mark protection sits alongside other intellectual property questions that brand owners face when expanding abroad. These recent analyses from our intellectual property coverage are a useful next read.

Topic	Analysis
Valuing and transferring brand IP	Aston Martin creditors challenge the transfer of its branding rights
Image and personality rights	Dua Lipa's Samsung claim and celebrity image rights
European patent enforcement	What UPC patent litigation is, after InterDigital v Disney
US patent damages	Apple's $5.7bn Taptic Engine verdict and how it could be reversed
Copyright and AI	Thomson Reuters v Ross and AI training as fair use

Frequently asked questions

What is an international trademark?

An "international trademark" usually means an international registration under WIPO's Madrid System: one application, based on a home mark, that designates several member countries. It is not a single worldwide right. Each designated office examines the mark under its own law and can refuse it, so the result is a bundle of national and regional rights managed centrally.

How much does it cost to have an international trademark?

Official fees combine the home filing, WIPO's basic fee of CHF 653 (CHF 903 in colour) and a fee for each designation. Designation fees range widely: CHF 220 for one class in China, CHF 789 for the EU and CHF 1,397 per class for Saudi Arabia. Attorney, search and translation costs come on top. WIPO's fee calculator gives exact figures.

How many countries does the Madrid Protocol cover?

Following Saudi Arabia's accession, effective on 8 October 2026, the Madrid System has 117 members covering 133 countries, according to WIPO, representing more than 80% of global trade. Some members are regional organisations, such as the European Union, so one designation can cover several countries. Protection in China does not extend to Hong Kong or Macao.

How much does an EU trademark cost?

Filing an EU trade mark online with the EUIPO costs €850 for one class, €50 for a second class and €150 for each further class. Registration lasts ten years and can be renewed indefinitely. Designating the EU through the Madrid System instead costs CHF 789 for the first class, CHF 48 for the second and CHF 144 for each further class.

How long is a UK trademark valid?

A UK registered trade mark lasts ten years and can be renewed every ten years indefinitely. Registration usually takes about three to four months if there are no objections or oppositions. Since 1 April 2026 an online application costs £205 for one class and £60 for each additional class. A mark not used for five years can be revoked.

What is a central attack under the Madrid Protocol?

For five years after an international registration, it depends on the home application or registration. If a third party succeeds in cancelling or limiting the home mark in that period, the international registration is cancelled to the same extent in every designated country. The holder can then transform designations into national applications within three months, keeping the original date.

Does a UK or EU trade mark protect my brand in China?

No. China operates a first-to-file system and does not recognise UK or EU registrations, so you need a Chinese registration, either through a Madrid designation or a direct filing with CNIPA through a local agent. Many brands also register a Chinese-character version of the mark. Hong Kong and Macao require separate filings.

What can I do if someone has registered my trademark abroad first?

Act quickly. If the application is still in its opposition window, file an opposition with evidence of your earlier rights. If it has registered, consider invalidation for bad faith, a non-use attack once the relevant period has passed, or negotiation. China's revised law, in force from 2027, adds fines of up to RMB 100,000 for bad-faith filers.

Should I use the Madrid System or file directly in each country?

Madrid usually suits brands targeting several member countries with a stable, cleared home mark, because it centralises filing and renewals. Direct filings suit a few key markets, countries outside Madrid, urgent launches or marks likely to face objections. Many brands combine both, so test the plan with a trade mark attorney before filing.

Sources

1. WIPO: Saudi Arabia joins WIPO's Madrid System (23 July 2026)
2. WIPO Information Notice No. 35/2026: Accession to the Madrid Protocol, Saudi Arabia (23 July 2026)
3. WIPO Information Notice No. 37/2026: Individual fee declaration, Saudi Arabia (1 September 2026)
4. WIPO: Madrid System members
5. WIPO: Schedule of fees under the Madrid Protocol
6. WIPO: Individual fees under the Madrid Protocol
7. WIPO: Madrid fee calculator
8. WIPO Lex: Protocol Relating to the Madrid Agreement Concerning the International Registration of Marks
9. WIPO Lex: Paris Convention for the Protection of Industrial Property
10. WIPO: Madrid System Yearly Review 2026 (13 May 2026)
11. EUIPO: Fees and payments
12. EUIPO: Opposition
13. EUIPO: FAQ on the EU trade mark application and registration procedure
14. GOV.UK: Register a trade mark
15. GOV.UK: Register a trade mark, after you apply
16. GOV.UK: Application to register a trade mark (Form TM3), updated 1 April 2026
17. Intellectual Property Office: New fees from 1 April 2026 for designs, trade marks and patents
18. GOV.UK: Fee sheet for international trade mark applications (FS4)
19. GOV.UK: EU trade mark protection and comparable UK trade marks
20. Trade Marks Act 1994, section 3
21. Trade Marks Act 1994, section 46
22. UK Supreme Court: SkyKick UK Ltd v Sky Ltd [2024] UKSC 36, press summary (13 November 2024)
23. European Commission China IP SME Helpdesk: Frequently asked questions
24. European Commission IP Helpdesk: Revised China Trademark Law to take effect on 1 January 2027 (4 August 2026)
25. European Commission IP Helpdesk: China's 2026 Trademark Law revision, 10 changes reshaping brand protection (6 August 2026)
26. China Daily: Trademark Law changed for fairer market (29 June 2026)
27. EUIPO TMview
28. WIPO Global Brand Database
29. WIPO Madrid Monitor
30. Global Law Experts: How to secure international trade mark protection (September 2026)
31. Global Law Experts: How to trademark a name in Belgium, BOIP vs EUIPO (June 2026)
32. Global Law Experts: How to protect and enforce famous foreign brands in China (September 2026)

About this article

This analysis was researched and written by The Corporate INTL Newsroom, which covers cross-border legal, regulatory and business developments for lawyers, professional advisers and financiers in over 150 jurisdictions. It has been checked against the Madrid Protocol and the Paris Convention, WIPO's information notices, fee schedules and statistics, EUIPO and UKIPO guidance and fee pages, the Trade Marks Act 1994, the UK Supreme Court's SkyKick judgment, the European Commission's China IP SME Helpdesk and reporting on China's revised Trademark Law, and guides published by our sister publication Global Law Experts. Official fees are those published on 11 October 2026 and change from time to time; Swiss franc amounts have not been converted because exchange rates move, and attorney, search and translation costs are not included. This article is general information, not legal advice; for advice on a specific filing, consult a qualified trade mark attorney. Last reviewed 11 October 2026. For more analysis like this, visit the Corporate INTL newsroom or subscribe to Corporate INTL.