US Trademark in Europe: Expansion Guide
A US registration does not cover the EU. For most brands, the right starting point is an EU trade mark (EUTM) covering all 27 member states.
Trade mark rights are territorial. A US federal registration gives you no enforceable rights in Europe, even if your brand is well known in the United States.
For most US brands expanding into Europe, the first step is an EU Trade Mark (EUTM) filed at the EUIPO. A single EUTM covers all 27 EU member states.
If you only need protection in a few countries — for example Switzerland, Norway or the UK — national registrations may be more cost-effective. The UK now sits outside the EU trade mark system, so a separate UK filing is usually needed.
The EU is generally first-to-file, although some unregistered rights exist. That means the risk of conflict rises once you announce a launch. Filing before marketing commits, signing franchise deals or approving distributor agreements is the safer approach.
For franchisors and licensors, the trade mark is often the core licensed asset. Securing it before negotiating master franchise agreements protects both control and royalty value.
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