EUROPEAN UNION
July 06, 2026
On July 1, 2026, the second phase of the amendment of design law in the European Union came into effect. This reform aims to adapt the regulations to the digital economy, digitization, and new forms of product marketing.
Although the reform began in 2025 with the adoption of the new regulatory framework, this second phase introduces significant practical changes that affect both those applying for design registration and the companies that exploit, manufacture, or market designs.
In this publication, we analyze the main changes introduced by Regulation (EU) 2024/2822, Commission Implementing Regulation (EU) 2026/138, and Decision EX-26-3 of the Executive Director of the EUIPO, which set forth the procedural and technical aspects applicable to European Union Designs as of July 1, 2026.
The implementation of these changes presents an opportunity to review your design protection strategy and ensure that new applications take full advantage of the possibilities offered by the new regulatory framework.
The number of views allowed for static designs is increased
Effective July 1, 2026, applicants will be able to include up to 10 views to represent a static design, compared to the previous limit of seven views.
This expansion allows the product to be shown in greater detail from different perspectives, facilitating a more precise definition of the design for which protection is sought. In addition, each image may have a maximum size of 2 MB in JPEG format, with a combined limit of 20 MB for all files attached to the application.
New types of design representations
In addition to traditional static representations, applicants can now submit dynamic representations and animated representations of their designs:
- Dynamic representations allow the design to be viewed in three dimensions (3D) from different angles using a file in OBJ or STL format, with a maximum of 20MB per file;
- Animated representations show movement, transitions, or other animation effects through an MP4 file of up to 20 seconds per view, with a maximum of 20MB per file.
For each application, a single type of representation (static, dynamic, or animated) must be selected.
However, although this new provision takes effect on July 1, 2026, it is important to note that these new formats are not yet accepted by all Intellectual Property Offices outside the European Union, which could pose limitations when claiming priority for applications in other jurisdictions.
Visual disclaimers
Phase II of the reform also specifies the use of visual disclaimers in design representations: these tools make it possible to clearly identify which elements of the image are not part of the design for which protection is sought and are particularly useful when only part of the product is intended to be protected or when certain elements appear in the representation solely for illustrative purposes.
The regulations require that these visual disclaimers be applied consistently across all views of the design and, furthermore, expand the methods that may be used, particularly in dynamic and animated representations, where techniques such as shading or blurring may be employed in addition to traditional broken lines.
Modification and alteration of a design’s representation
Since the implementation of the second phase of the reform, it is permitted to correct minor errors in the representation of a design (provided they are immaterial details and do not alter the essential identity of the design) without losing the original filing date of the application. This prevents the applicant from losing priority when correcting minor formal errors.
Classification and indications of products
Phase II of the reform introduces greater flexibility in the management of product designations included in design applications. When the applicant uses a designation that does not appear in the Locarno Classification, does not correspond to the indicated class, or does not match the representation of the design, the EUIPO may, on its own initiative, amend that designation to bring it into line with the correct terminology.
- If the applicant has previously authorized this action, the Office will make the correction and continue prosecuting the application without issuing an office action, provided there are no other deficiencies;
- Otherwise, the EUIPO will notify the applicant of the irregularities so that the applicant may correct them.
Fully digital communication
The second phase of the reform also consolidates the digitization of procedures related to European Union Designs by stipulating that all communications, notifications, and filings addressed to the EUIPO must be made exclusively by electronic means.
Streamlined invalidity proceedings
Improvements are also being introduced to the procedures for declaring designs invalid, with the aim of strengthening legal certainty and streamlining the resolution of these cases. The new regulations require the applicant for invalidation to include a statement of grounds setting forth the facts, evidence, and arguments supporting the grounds alleged.
Advice on registering designs
At UNGRIA, we have a team specialized in designs that can advise you on the protection, registration, and management of your designs, both within the European Union and internationally.
Please, do not hesitate to contact us for more information.