Selling or Manufacturing Abroad? Why UK Registration Isn't Enough

27 Oct 2026

British jewellery has a global reputation, and more jewellers than ever are reaching beyond the UK. You might have pieces cast or set by an overseas manufacturer, sell to customers in Europe or the US through your website or marketplaces, or exhibit at international fairs.

It's an exciting step, but there's one assumption that catches many businesses out: that registering your brand or designs in the UK protects you everywhere. It doesn't.

Here's what every jeweller should know before taking their business abroad.

Why UK protection stops at the border

Registered trade mark and design rights are territorial. A UK registration provides protection in the UK; protection in overseas markets generally needs to be secured separately.

Brexit made this distinction particularly important. UK registrations and EU registrations are now separate rights. Since the end of the Brexit transition period, a new EU trade mark or registered EU design does not provide protection in the UK, so businesses seeking protection in both markets generally need rights covering both territories.

Many countries place significant weight on who files first. In some jurisdictions, an earlier user may have limited ability to prevent a later applicant securing registered rights, so relying solely on earlier UK use can be risky.

A reputation or earlier use in the UK does not automatically give you enforceable rights in another country.

The real risks for jewellers

• Your manufacturer registers your brand. An overseas manufacturer, distributor or agent may apply to register your brand in its own name. Depending on the jurisdiction and circumstances, that could make it more difficult or expensive for you to use, register or enforce your brand in that market.
• Copies can be harder to challenge. If a lookalike of your signature collection appears in a country where you have no registered rights enforcement can be more difficult. Other rights may sometimes assist, but this will depend on the law of the country concerned.

Trouble at trade fairs. Showing new pieces at an international fair puts your designs in front of thousands of buyers and competitors. Disclosing a new collection before appropriate applications have been filed can also affect your ability to obtain design protection in some countries, making pre-launch filing particularly important.

• Being forced to rebrand. If someone already owns your name in a new market, you may have to sell under a different name there or buy it back at a high price.

Your options for international protection

• Country-by-country filing. You apply directly in each country you care about, such as the US.

EU-wide protection. An EU trade mark can provide unitary trade mark protection across all EU Member States. For designs, EU-wide registered design protection can similarly be obtained through the EUIPO.

• International filing systems. The Madrid System for trade marks and Hague System for designs can provide a more streamlined route for seeking protection in multiple participating territories through an international application. Protection remains subject to the requirements of the territories designated.
• A particular warning for jewellery designs: timing matters. Publicly displaying, advertising or selling a new design before filing can affect its eligibility for registered design protection in some countries. Although some jurisdictions provide grace periods, others are less forgiving, so the safest approach is to consider design filings before the collection is disclosed.

When to act: five practical steps

1. Plan international protection early. If overseas markets are important, consider them when making the initial UK filing. International priority periods can be short, so obtaining advice early can preserve filing options and priority dates.

2. Map your markets. List where you manufacture, where you sell (including online) and where you exhibit. These are your priority countries.

3. File before you disclose. Where possible, file design applications before sending new designs to overseas manufacturers, exhibiting new collections or otherwise making them public. Disclosure before filing can prejudice design protection in some jurisdictions.

4. Get agreements in writing. NDAs and manufacturing agreements should confirm you own your designs and brand, and stop suppliers registering or selling them.

5. Watch the registers. Monitoring alerts you if someone tries to register a similar brand in your key markets, while there's still time to oppose it.

How NBR can help

At National Business Register Group (NBR), we help UK businesses protect their brands and designs at home and abroad. We work with jewellers to:

• register trade marks and designs in the UK, EU and further afield
• advise on which markets to prioritise, so you're not paying for protection you don't need
• draft NDAs and manufacturing agreements for overseas suppliers
• monitor international registers for copycat filings

For more information, you can contact the team on 0800 069 9090 or info@nbrg.co.uk.

View National Business Register

Source: National Business Register