EU Design Reform: A Complete Guide to the Changes Introduced in 2025 and 2026

The European Union designs regime has undergone its most significant overhaul in more than two decades. The reforms, introduced in two phases between May 2025 and July 2026, modernise EU design law to better accommodate digital products, graphical user interfaces (GUIs), animation, 3D printing technologies, typographic typefaces, and virtual goods. They also introduce important procedural changes affecting the way designs are filed, represented and enforced.

For businesses relying on design protection, understanding these changes is essential to ensuring that valuable product designs, digital assets and branding elements remain adequately protected.

Phase 1: The New EU Designs Regulation (1 May 2025)

The first phase of reform came into force on 1 May 2025 and introduced a number of substantive changes to EU design law. 

Registered Community Designs Become Registered EU Designs

One of the most visible changes is the rebranding of the EU design system. The former "Registered Community Design" (RCD) has been renamed the "Registered European Union Design" (REUD), bringing design terminology into line with EU trade mark practice. A new registered design symbol, Ⓓ, was also introduced, allowing rights holders to indicate that a product is protected by a registered EU design.

Expanded Protection for Digital and Animated Designs

Historically, EU design law was drafted largely with physical products in mind. The new legislation expressly recognises that modern products are increasingly digital and interactive.

The definition of a "design" has been expanded to include features such as movement, transition and animation, making it clear that animated graphical user interfaces and other dynamic visual elements can benefit from design protection. 

Similarly, the definition of a "product" now extends beyond physical objects to include non-physical products materialised in digital form. As a result, virtual goods, virtual environments, metaverse assets and other purely digital products can now be expressly protected through the EU design system. 

Stronger Protection Against 3D Printing and Digital Manufacturing

The reforms also strengthen enforcement rights in response to the growth of additive manufacturing and 3D printing.

Design owners now have enhanced rights against the unauthorised creation, sharing, downloading and distribution of digital files that record protected designs for manufacturing purposes. This means that EU design rights can be used more effectively against unauthorised CAD files, 3D print files and online file-sharing platforms that facilitate infringement.

Expanded Customs and Anti-Counterfeiting Measures

The scope of protection has also been broadened to address counterfeit products passing through Europe.

A registered EU design may now be enforced against counterfeit goods transiting through the EU, even where those goods are not intended for release onto the EU market. This change aligns EU design rights more closely with EU trade mark rights and strengthens border enforcement options. 

New Defences to Design Infringement

The reforms introduce several new limitations and exceptions to infringement.

Certain acts carried out for the purposes of identification, reference, commentary, criticism or parody may now be permissible, provided they are consistent with fair commercial practices and do not unreasonably prejudice the design owner's interests. 

The Permanent Repair Clause

One of the most commercially significant changes concerns spare parts.

The reformed legislation cements the so-called "repair clause", which limits the ability of design owners to enforce design rights against certain component parts used solely to repair a complex product and restore its original appearance. 

The change is intended to enhance competition in the spare-parts market and support broader sustainability initiatives by encouraging repair rather than replacement. Note, however, that third parties seeking to take advantage of this defence must comply with a number of other requirements, such as clearly identifying the manufacturer of the spare part so that consumers are able to make an informed decision about whether to purchase OEM equipment or aftermarket parts.

Changes to Filing Practice

The 2025 reforms also introduced important procedural changes, including:

• simplified and consolidated filing and publication fee structures, including the requirement to pay all fees upfront;
• reduced fees for additional designs within multiple applications;
• significant increases to renewal fees, particularly for later renewal periods;
• automatic publication of deferred applications at the end of the deferment period, and the requirement that deferred designs must be actively surrendered before the end of the deferment period to avoid publication;
• removal of the requirement that all designs within a multiple application belong to the same Locarno class; and
• a new limit of 50 designs per multiple application. 

The removal of the Locarno class restriction is particularly beneficial, allowing applicants to include designs relating to different categories of products within a single multiple application.

Phase 2: The New Implementing Regulation (1 July 2026)

The second phase of reform came into effect on 1 July 2026 and focuses primarily on modernising the way in which designs are represented and filed before the EU Intellectual Property Office (EUIPO). 

Removal of the Seven-View Limitation

For many years, applicants were restricted to seven static views when filing an EU design application.

The new regime removes this restriction, giving applicants much greater flexibility in how they represent their designs. This is particularly valuable for products with complex geometries, multiple positions or interactive elements that cannot be adequately represented using only a handful of images. 

Subsequent EUIPO guidance indicates that static-view filings may now include up to ten views per design. 

Acceptance of Animated and Dynamic File Formats

Perhaps the most significant development is the EUIPO's acceptance of animated and dynamic design representations.

Applicants may now submit:

• Animated representations in MP4 format; and
• 3D CAD-based dynamic views using OBJ and STL files. 

These new formats allow applicants to protect features that are difficult to communicate through static images alone, including:

• animated GUIs;
• screen transitions;
• products with moving components;
• products that change configuration over time; and
• complex three-dimensional shapes and surfaces. 

Greater Opportunities for Digital Products

The reforms are especially important for technology companies, software developers, gaming businesses and manufacturers of connected products.

Animated user interfaces, virtual reality environments, digital-only products and products incorporating motion-based visual features can now be represented more effectively using file formats that reflect how the design is actually experienced by users. 

However, while GUIs and digital products are protectable, software itself remains excluded from design protection.

New Rules on Multiple Applications

The EUIPO has confirmed that multiple applications may contain up to 50 designs, subject to an overall file size limit of 200 MB. 

Limited Ability to Correct Design Representations

Historically, errors in filed representations could be difficult to rectify.

Under the revised regime, amendments may be permitted both before and after registration where they relate only to immaterial details. This provides greater flexibility and reduces the need for complete refiling in certain circumstances. 

Practical Considerations for Applicants

Although the reforms are overwhelmingly positive, applicants should proceed carefully.

Dynamic CAD formats such as STL and OBJ files have technical limitations. For example, STL files cannot store colour or texture information, while CAD files may display differently depending on the software used. Where colour, texture or material characteristics are important aspects of the design, traditional static representations may still be preferable. 

There are also international filing considerations. While the EUIPO now accepts dynamic and animated formats, many other design offices around the world do not. Businesses intending to rely on priority rights for international filings should therefore consider filing corresponding static representations alongside any animated or dynamic EU design applications. 

What Do These Reforms Mean for Businesses?

The EU design reforms represent a substantial modernisation of the European design protection system.

For the first time, EU design law fully embraces digital products, virtual environments, animation and advanced manufacturing technologies. At the same time, the procedural reforms provide applicants with far greater flexibility when representing complex designs and filing multiple applications. 

Businesses developing innovative consumer products, software interfaces, digital assets, virtual goods or advanced manufacturing solutions should review their design protection strategies to ensure they take full advantage of the expanded opportunities now available under the EU design regime.

Subscribe to receive more articles like this here.