Since 1 July 2026, the second stage of the EU design reform has been in force. The first stage in May 2025 brought, among other things, new fees – the amounts, which we have compiled in our post on EU design costs, remain unchanged. The second stage concerns the core of every design application: the representation of the design. It determines what is protected, because protection only extends to what is visible in the application. The legal basis is the newly codified Regulation (EU) 2026/715, Delegated Regulation (EU) 2026/137 and Implementing Regulation (EU) 2026/138, together with new EUIPO examination guidelines.
Three forms of representation: images, 3D model or video
Until now, an EU design could only be filed with up to seven views in JPEG format – fewer than for a German design, for which the DPMA has long allowed ten representations. Applicants can now choose between three forms of representation:
- Static representation: up to ten views instead of the previous seven, each as a JPEG file of no more than 2 MB, in black and white or in colour.
- Dynamic representation: a digital 3D model as an OBJ or STL file (maximum 20 MB) that can be viewed from all sides in the register. These formats do not, or only partly, reproduce colours, surfaces and materials – they are suitable where the shape is what matters.
- Animated representation: a video in MP4 format (maximum 20 MB, without sound) for designs whose appearance lies in a movement or transition – such as animated icons, menus or moving product parts. Since the reform, movement and animation are expressly eligible for protection, as are digital products such as user interfaces.
Only one form of representation is permitted per design; a 3D model cannot be combined with supplementary individual views. Anyone wishing to secure both files two designs – in a multiple application at 125 euros for each additional design.
Filing date and subsequent corrections
A neutral background and a particular image quality are no longer requirements for the filing date; what matters is that the design is clearly identifiable. It is also new that the representation can be amended in immaterial details – before and after registration, subject to an official fee and without losing the filing date. This makes it possible, for example, to neutralise a distracting background. The scope of protection must not change as a result; this is not an opportunity to improve the design itself. How narrowly the EUIPO will interpret "immaterial" remains to be seen in practice. Since July, all communication with the Office has also been entirely electronic.
What has already applied since May 2025
The changes of the first stage remain in place: a multiple application can contain up to 50 designs, including products from different classes – for example, a piece of furniture and its packaging in one application. Applications are filed exclusively with the EUIPO and no longer via national offices.
What applicants should bear in mind
The form of representation should be decided before filing, because it defines the subject matter of protection. Elements for which no protection is claimed must be identified consistently in all views – for images usually by broken lines, for 3D models and videos for instance by blurring or colour shading. Anyone who intends to file the design outside the EU as well within the six-month priority period should also bear in mind that many offices do not yet accept 3D files and videos. In that case, an additional application with conventional views as a basis for priority is advisable.
For most products, filing with photographs or drawings remains the norm – now with up to ten views and somewhat more leeway for corrections. The new formats are particularly worthwhile for digital products and complex shapes.