Trademark Registration in the United Kingdom & Ireland: Country Reference
Ireland remains an EU member covered by an EU Trade Mark. The United Kingdom left the EU and is not covered — meaning two adjacent English-speaking markets now require two separate rights.
This page is a general information reference on how trademark protection is structured in these jurisdictions. It is not legal advice, and it does not represent that this firm practises before the national offices listed. For filings from Pakistan, see our guide to the Madrid Protocol route. Anyone searching for the best trademark lawyer in Pakistan for UK protection needs to know an EU trademark filed today does not cover Britain at all, since Brexit.
These two markets are usually approached together — shared language, closely linked commerce, overlapping distribution — and are now on opposite sides of the EU trademark boundary.
Ireland — IPOI, and still inside the EUTM
Ireland is an EU member state and remains fully covered by an EU Trade Mark. National filings are available through the Intellectual Property Office of Ireland (IPOI). For a business already holding an EUTM, Ireland needs no additional action. Ireland's position also makes it, post-Brexit, the primary English-language jurisdiction inside the EU trademark system.
The United Kingdom — outside it since Brexit
The UK is no longer covered by an EU Trade Mark. Protection requires a separate application to the UK Intellectual Property Office (UKIPO), or a Madrid Protocol designation of the UK. This is examined under UK law, on a UK timeline, with its own opposition window and renewal cycle. Our dedicated page on UK registration after Brexit covers the detail, including what happened to EUTMs that predated the split.
Northern Ireland
Northern Ireland is part of the United Kingdom and is covered by UK trademark rights, not by EU ones — notwithstanding the distinct arrangements that apply to goods movement under the post-Brexit protocol arrangements. For trademark purposes it follows the UK, not Ireland. Businesses distributing across the island of Ireland therefore need both rights to cover the whole island.
Why this pairing matters for Pakistani exporters
Given the scale of Pakistan–UK trade and the size of the British Pakistani consumer market, the UK is frequently the first European market a Pakistani brand enters — and Ireland often follows as the English-language route into the EU. A business planning both needs to understand from the outset that this is two filings, not one, and that an EUTM covers only the second of them.
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Official sources
Common questions
Does an EU Trade Mark still cover the United Kingdom?
No. Since Brexit, the UK Intellectual Property Office operates entirely separately from the EUIPO, and an EU Trade Mark filed today gives no protection in the UK. Ireland remains an EU member and is still covered by an EUTM.
Which is the more important market for a Pakistani exporter — the UK or Ireland?
Given the scale of Pakistan-UK trade and the size of the British Pakistani consumer market, the UK is frequently the first European market a Pakistani brand actually enters — and it is the one an EU Trade Mark does not reach at all, making a separate UK filing a priority rather than an afterthought.
For the specific mistake exporters make when they assume an EU Trade Mark covers the UK, see our dedicated Brexit trademark guide.
This article is general information about Pakistani law and procedure, not legal advice for any specific matter. If this touches on something you're currently facing, get in touch and we'll advise on your facts directly.