New EUIPO procedures 2026: what changes for companies registering designs

Key data

If your company registers industrial designs in the European Union, the procedures you have been following until now have changed. The Delegated Regulation (EU) 2026/1841, published on 28 October 2026, establishes new detailed rules for procedures before the EUIPO and entirely repeals the previous Delegated Regulation (EU) 2026/137.

This is not a minor change in form: the regulation specifies the details of the procedures for registration, modification and management of EU designs. Any company that has been following the procedures of the previous regulation must review whether its internal processes remain valid.

What does this regulation establish?

Delegated Regulation (EU) 2026/1841 completes the regulatory framework of Regulation (EU) 2026/715, which is the "parent" regulation on EU designs approved by the European Parliament and the Council. This delegated regulation specifies the procedural aspects that the main regulation left for later development.

Specifically, the new regulation governs the details of the following procedures before the EUIPO:

• Registration of EU designs: new submission requirements, admitted formats and applicable deadlines.
• Modification of registered designs: updated procedures for requesting changes to existing registrations.
• Management of registered designs: procedures for maintenance, renewal and other administrative management before the EUIPO.

Comparison: previous regulation vs. new regulation

Economic and operational impact

The direct impact of this regulation is not a new fee or automatic penalty: it is an operational adaptation cost. Companies managing portfolios of designs registered with the EUIPO will need to review and update their internal processes to ensure they comply with the new submission requirements, deadlines and formats.

Adaptation costs vary depending on the volume of active registrations and the complexity of each company's design portfolio:

• Companies with large design portfolios (fashion, automotive, consumer technology): greater effort in reviewing and updating internal procedures.
• Law firms and industrial property agents: need to update templates, workflows and client communications.
• SMEs with occasional registrations: lower impact, but they must still verify that pending or future procedures comply with the new requirements.

The risk of not adapting is concrete: a submission presented with formats or deadlines from the previous regime could be rejected by the EUIPO, which would imply delays in design protection and potential loss of rights against third parties.

Who does it affect?

• Fashion and textile sector: companies registering collections, prints and product designs with the EUIPO.
• Technology sector: manufacturers of devices, accessories and components with designs registered in the EU.
• Automotive sector: manufacturers and suppliers protecting designs of bodies, interiors and components.
• Consumer goods sector: companies in packaging, appliances, furniture and mass-market products.
• Industrial property agents and agencies: professionals managing registrations with the EUIPO on behalf of third parties.
• Internal legal and IP departments: teams managing intellectual and industrial property portfolios in medium and large companies.
• Independent designers: professionals registering their creations directly with the EUIPO.

Practical example

A Spanish fashion company with a portfolio of 40 designs registered with the EUIPO plans to renew 12 of them and file 8 new applications in the coming months. Until now, its legal department followed the procedures established in Delegated Regulation (EU) 2026/137.

With the entry into force of Delegated Regulation (EU) 2026/1841, this company must:

1. Review whether the design representation formats it regularly uses remain valid under the new requirements.
2. Verify the new deadlines applicable to the 12 planned renewals to avoid expiration.
3. Update the application templates it uses for the 8 new submissions, adapting them to the new submission requirements before the EUIPO.

If it does not conduct this review and submits applications with formats from the previous regime, the EUIPO could request corrections or, in the worst case, reject the applications, leaving the designs unprotected during the resolution period.

What should companies do now?

1. Identify all active design registrations with the EUIPO and pending procedures (renewals, modifications, new applications).
2. Review the new procedural requirements of Delegated Regulation (EU) 2026/1841, especially deadlines, admitted formats and submission requirements.
3. Update internal processes and templates used by the legal department or industrial property agent to adapt them to the new regime.
4. Inform external agents (law firms, IP agencies) managing registrations on behalf of the company to ensure they have also updated their procedures.
5. Review ongoing procedures initiated under Delegated Regulation (EU) 2026/137 to verify if they need to be adapted to the new regulation.
6. Consult directly with the EUIPO or a qualified industrial property professional if you have any doubts about applying the new procedures to specific cases.

Official source

Consult full regulation at official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202601841