EU design reform: second phase takes effect

The second phase of the EU design reform entered into effect on 1 July 2026, bringing further practical changes to the EU design protection system.

The reform package represents the first substantive update to the EU design system in more than 20 years and is intended to simplify the law, clarify what can be protected, and better align design protection with modern business and technological developments.

In our previous article, Update on EU design reform, we looked at the first phase of the reform, which took effect on 1 May 2025. That phase introduced important changes to official fees, removed the “unity” requirement for multiple design applications, amended the examination process and the mechanism for deferred publication, and introduced the new registered design symbol.

The second phase builds on these changes. It is particularly relevant for businesses whose products are experienced digitally or on screen, making design protection more relevant to the way products are designed, marketed and used today.

Greater flexibility in design representations

A key feature of the second phase is the greater flexibility around the types of designs that can be represented and protected. The changes are expected to make the EU design system better suited to modern visual assets, including graphical user interfaces, screen-displayed designs, animated designs, transitions, computer-generated designs and other digital or technology-driven product features.

One important practical change is the increase of the previous seven-view limit for an EU design application to ten views. This should allow applicants to present designs more effectively, particularly where a small number of static images may not be sufficient to capture the relevant visual features of a complex or animated design.

The new framework is also intended to better accommodate modern filing formats, including visual sequences and dynamic representations, subject to applicable technical requirements. In particular, it is now possible for applicants to file an animated representation to show the movement, transition or any other sort of animation of design features in a continuous visual representation (for example, by filing a video).

The increase in the number of views and the option to file dynamic representations should provide more scope to capture animated and transitioning digital designs. This will be particularly relevant for businesses in sectors such as software, e-commerce, gaming, consumer electronics, fintech, digital platforms and connected devices, where product appearance is often expressed through digital interfaces and movement rather than purely physical form.

Portfolio review

For rights holders, the second phase of the reform is a useful prompt to review existing design portfolios and filing strategies.

Businesses may wish to consider whether digital assets, user interfaces, app screens, website layouts, animations, on-screen product environments or other visual features could now be protected more effectively through EU design rights.

Early review may be particularly important where designs have already been disclosed, given the continuing relevance of the 12-month grace period.

What should rights holders do now?

Rights holders should consider:

• reviewing existing design portfolios to identify any gaps in protection;
• assessing whether digital interfaces, animations or screen-based assets may now be more suitable for registration;
• reviewing filing practices for multiple design applications and design representations;
• considering whether upcoming product launches include visual assets that should be protected before disclosure; and
• seeking advice on how best to represent complex, animated or digital designs in an application.