30/06/2026
The reform of EU design law is being implemented in two stages. The first phase came into force on 1 May 2025, introducing a number of significant changes to the EU design system. The second phase of the reform takes effect on 1 July 2026 and introduces further changes to filing requirements and EUIPO procedures.
For a reminder of the Phase 1 changes, including the revised fee structure, the removal of the same-class requirement for multiple design applications and the broadened definitions of “design” and “product”, please see our previous article here.
Below, we highlight some of the key changes coming into force from 1 July 2026.
No more seven-view limit
Under the previous regime, applicants were limited to seven views when filing a registered EU design. It was also possible to include up to three additional unpublished and unprotected views for explanatory purposes.
From 1 July 2026, that limit disappears entirely.
Article 36 of the Community Design Regulation, as amended by the EU Design Reform legislation, sets out the requirements for representing a design but no longer imposes a maximum number of views. Instead, all views must be consistent with one another and, taken together, clearly disclose the design for which protection is sought.
This change will be particularly beneficial for:
- complex products;
- products with numerous features or components;
- modular products; and
- animated or dynamic designs.
In many cases, seven views were simply insufficient to fully illustrate the design.
The EUIPO is expected to impose a technical limit based on system capabilities, and further guidance should be provided in the updated EUIPO Guidelines. By way of comparison, the UK Intellectual Property Office currently allows up to 12 views in online design applications.
Video and 3D models now permitted to represent a design
One of the most significant practical consequences of the broader definition of a “design” introduced in Phase 1 is the expansion of the ways in which a design can be represented.
The reform package introduces the possibility of representing designs using modern technologies, including video, computer imaging and computer modelling. Article 26 of Directive (EU) 2024/2823 expressly provides that a design representation may be static, dynamic or animated and may be affected by any appropriate means using generally available technology. The corresponding EUIPO technical requirements are expected to apply from 1 July 2026.
This represents a major development for animated, digital and virtual designs.
Rather than attempting to represent movement through a series of static images, applicants will be able to submit a video file showing the movement itself. Similarly, 3D models may be used where they provide a clearer and more accurate representation of the design than traditional two-dimensional drawings.
The EUIPO has yet to confirm the accepted file formats and file size limitations. However, given that the EUIPO already accepts video files for multimedia trade marks, it is anticipated that similar formats will be permitted for design applications.
As always, the scope of protection will continue to be determined by the representations filed. Accordingly, applicants should carefully consider how best to represent their designs to maximise protection while ensuring consistency across all submitted materials.
Amendment of Representation
One of the most welcome practical changes introduced by Phase 2 is the new ability to correct certain errors in a filed design application.
Previously, where inconsistencies existed between drawings or views, applicants often had limited options. In many cases, the only solution was to delete the problematic view or divide the application into separate designs.
From 1 July 2026, new Article 47a introduces a procedure allowing applicants to amend the representation of a filed design in respect of “immaterial details”.
Importantly, any amendment must not alter the scope of protection of the design.
Amendments may be requested:
- in response to an EUIPO notification of irregularities; or
- on the applicant’s own initiative during the registration process.
The official fee for requesting an amendment will be EUR 200 per request.
This update conforms to the UK IPO where amendments to drawings, while not explicitly provided as an option often on communications, generally are allowable when they do not alter the scope of protection of the design.
It remains to be seen how narrowly or broadly the EUIPO will interpret the concept of “immaterial details”. Early decisions under the new regime will therefore be of particular interest.
New Requirements for Recording Assignments at EUIPO
From 1 July 2026, documentary evidence of a transfer must be provided when recording an assignment of a Registered EU Design at the EUIPO.
While written assignment agreements are already standard practice in most commercial transactions, the new rules make clear that sufficient evidence of the transfer must be supplied before ownership changes can be recorded on the EU register.
Applicants and rights holders should therefore ensure that appropriate assignment documentation is retained and readily available.
A Faster Route for Uncontested Invalidity Actions
Phase 2 also introduces a streamlined procedure for certain invalidity actions.
Under Article 7 of Commission Delegated Regulation (EU) 2026/137, where an invalidity action is based on a lack of novelty or individual character, and the design holder does not contest either the grounds for invalidity or the relief sought, the EUIPO must determine the action as a matter of priority.
The new procedure is intended to improve efficiency and reduce unnecessary delays in straightforward cases where there is no substantive dispute between the parties.
Next Steps
The EUIPO is expected to publish updated Guidelines and technical requirements before the new rules take effect. We will continue to monitor developments and provide updates as further details become available.
At Reddie & Grose LLP, we regularly assist companies and overseas counsel with European design protection and filing strategy. If you would like to discuss how the reforms may affect your filing strategy or existing design portfolio, please contact a member of our Designs team.
This content is for general information only. Its content is not a statement of the law on any subject and does not constitute advice. Please contact Reddie & Grose LLP for advice before taking any action in reliance on it.
