EU Design Reform: New Guidance on Animated and Dynamic Designs

Earlier this week, the EUIPO has issued further guidance on the Phase 2 implementation of the EU design reform, due to come into effect on 1 July 2026. This guidance provides important clarification on the use of animated and dynamic representations in EU design filings, reflecting a more modern and flexible approach to design protection.

The changes are particularly relevant for digital products, graphical user interfaces (GUIs), and products with moving or transitional features, where traditional static images may not fully capture the design.

Welcome Changes

Dynamic and animated views 

In addition to the previous practice of using static JPEG file format images, the updated guidance confirms that applicants will be able to file animated representations (in .mp4 format) and CAD-based dynamic views (using .OBJ and .STL files). These file types allow aspects of a design to be shown that are difficult, or sometimes impossible, to convey using static images alone, such as designs that comprise complex contouring or curvature, or complex animated sequences.

An example provided by the EUIPO of how a dynamic view will be represented on the register is shown here. 

These new formats are particularly valuable for:

• Animated graphical user interfaces (GUIs) and displays, where movement and transitions form part of the overall visual impression.
• Products with moving parts or transitional features, possibly allowing a clearer demonstration of how a product changes over time.
• Complex shapes and surfaces, where a dynamic CAD file may better communicate curvature and geometry than multiple static views

In practice the use of animated and dynamic representations can provide a more complete understanding of a design and help to reduce ambiguity in the design. For certain sectors the ability to file animated and dynamic representations will provide meaningful new opportunities for registered design protection. 

Number of views

The EUIPO has indicated that for designs depicted by static views, each design may now include up to 10 views. This long anticipated change is particularly welcome and will allow applicants to illustrate complex geometry or alternative configurations of moveable elements more clearly without sacrificing key orthogonal views.

Where a dynamic or animated representation is used, only one such view (of max 20 MB) may be filed per design, and the respective design cannot be supplemented with static views.

Number of designs in a multiple application

The EUIPO confirmed that they will accept up to 50 designs in a multiple design application, subject to a total file size of 200MB. 

Alterations

Historically, the EUIPO did not permit amendments to filed design representations. Any error typically required the removal of a view, or refiling the design resulting in a new filing date.

The new guidance indicates that amendments may be permitted both before and after registration, but only in respect of immaterial details. This approach is consistent with Article 50(e) of Regulation (EU) 2024/2822, which amended the Community Design Regulation and entered into force last year.

File with Caution

While the reforms are welcome, the guidance highlights several important limitations and practical considerations that applicants should bear in mind.

Dynamic view file types

Dynamic views may be filed using OBJ or STL files, but both formats have inherent limitations. STL files cannot store colour, texture, or material properties and represent curved surfaces using a triangular mesh, which may result in relatively coarse geometry. OBJ files can support colour and texture, but they do not generally store parametric data. 

The EUIPO has acknowledged these limitations and advises that CAD files should not be relied upon to show features relating to colour, texture, or materials, as these may display differently depending on the software used. Where protection of these characteristics is important, static image representations remain the safer option.

Where a design seeks to show movement or transition using dynamic views, the guidance indicates that separate designs may be required to protect different aspects of that movement.

Priority 

Although the EUIPO is leading the way in accepting dynamic and animated file types, many other design offices do not currently accept these formats. As a result, first filing in the EU using only dynamic or animated representations may create challenges for subsequent priority filings that must rely on static views. For this reason, where applicants wish to first file animated or dynamic designs at the EUIPO, it is strongly recommended that corresponding static view designs are filed alongside them.

Additionally, it is unclear how priority will be assessed if filing a dynamic or animated file type design at the EUIPO which makes claim to priority from a static view design. Therefore, when filing any priority claiming designs, for the time being it is recommended that static view designs are filed alongside any dynamic or animated designs. 

Animated designs

Care should be taken when using animated designs to protect product movement or transitions, such as a product moving from a closed to an open configuration. The EUIPO has indicated that, in such cases, protection may be interpreted as covering the transitional movement itself, rather than the individual static configurations.

Disclaimers

Traditional disclaimer techniques used for static designs, such as broken lines, are not easily applied to dynamic or animated representations. The guidance suggests that visual disclaimers such as blurring or colour shading may be acceptable, but these can be technically difficult to implement consistently. 

The EUIPO anticipates that new forms of disclaimers may emerge over time and has indicated that harmonised practices will be developed once these become established. Accordingly, until this is established, it is recommended that a cautious approach is taken when applying disclaimers to dynamic or animated designs to ensure that the disclaimer is consistent across the entire design (e.g. in all orientations of the dynamic view).

The need to be able to protect complex designs is further reinforced in a recent survey by the EUIPO which found that nearly three‑quarters of consumers are willing to pay more for well‑designed products, underscoring both the value of design and the importance of legal frameworks capable of protecting increasingly complex designs.

The Phase 2 reforms are due to come into force on 1 July 2026. We will be closely monitoring any further guidance issued by the EUIPO and how the Phase 2 reforms are implemented in practice.