From August 1st, trademarks registered to cover the UK will no longer automatically include Jersey. For their trademark to apply to Jersey this must now be selected separately.
As a result, companies in the UK risk being caught out by their existing trademarks no longer applying to the island of Jersey.
Businesses could also be at risk of protecting their trademarks in the wrong markets and incurring unnecessary costs of £700 on average per market.
To help UK companies better understand which markets they need to register trademarks in, Conrad Fahrenkrug, International Intellectual Property Counsel at iGERENT, has shared his expert advice to help companies avoid being caught out by potentially costly trademark registration mistakes.
Do UK companies need a trademark registration in Jersey or other international markets?
Whether or not a UK company requires a trademark registration for markets outside of the UK depends on a number of factors. Conrad explains when international protection may not be needed:
“International registration may not be a priority when overseas sales are occasional, customers are not actively targeted and the business has no local partners, manufacturers or realistic expansion plans. Protection should follow genuine commercial activity rather than a general ambition to become “global”.”
“From 1 August 2026, designating the UK through the Madrid System no longer automatically includes Jersey, which must now be selected separately where protection is needed. The change highlights a wider issue for UK businesses: trademark coverage should never be assumed and should reflect where a company actually sells, manufactures or plans to expand.”
Conrad outlines how this might apply to an e-commerce brand that accepts orders through its website from customers around the world:
“Occasional purchases from the US or EU, without local advertising, stock, distributors or marketplace activity, would not necessarily justify registration in every country where an order originates.
“The position changes when the business deliberately enters a market—for example, by launching a US-facing website, advertising locally, selling through a US marketplace or using a local fulfilment centre—making trademark protection more relevant before substantial investment is made.”
Registering trademarks in the wrong markets can cost companies £700 each
Across ten commercially significant markets, adding a country or regional registration costs approximately £700 on average, meaning that selecting five unnecessary markets could create around £3,500 in avoidable upfront costs. Those costs continue after registration: renewing a one-class portfolio across the UK, EU, US and China would involve approximately £1,500 in official fees every ten years, rising to more than £2,100 for two classes.
Conrad advises businesses to seek professional advice when choosing international markets to register trademarks in to help them avoid unnecessary costs:
“Each additional market can add around £700 to the initial filing budget. Professional advice can help businesses prioritise the markets that genuinely matter and avoid spending thousands of pounds on protection with little commercial value.
“The goal is not to register in as many markets as possible, but to secure the right protection at the right time, before expansion turns a preventable issue into a costly dispute.”
The Jersey change does not mean every UK company needs another registration, but it is a timely reason to check what existing protection actually covers. Conrad advises:
“Businesses should review their portfolio when overseas expansion becomes realistic, when local partners or manufacturers become involved and before registrations are renewed.