Yes, within limits. A UK trademark covers your name, logo or tagline in the UK and the Isle of Man, and it stops there, but you don’t have to file in every country on day one. The trademark priority period gives you six months from your first filing to apply in other Paris Convention countries and have those later applications treated as if they had been filed on your original date.
That six months is one of the most useful and least understood tools in trademark strategy. Apple has just given us a very clean example of it in action.
What does Apple’s iPhone Duo filing show about the trademark priority period?
It shows how a business can file quietly in one country first, then file elsewhere within six months and keep the earlier date. On 12 March 2026, Apple filed a trademark application for IPHONE DUO in Liechtenstein. On 9 September 2026, it filed in the US for smartphones and phone cases, and the US application record (serial number 50098431) lists that Liechtenstein application as its foreign priority basis. The same day, Apple unveiled iPhone Duo, its first foldable iPhone.
Count the days and the US filing lands 181 days after the Liechtenstein one, just inside the six-month window.
Why does that matter? Because it means Apple secured a March filing date for the name while keeping it largely out of the spotlight until launch day. If anyone had tried to file IPHONE DUO in the US over the summer, Apple’s claimed March date would sit ahead of theirs, provided the priority claim holds up.
You don’t need to be Apple to use the same rule. For a smaller business the benefit is arguably bigger, because six months is exactly the kind of breathing space a growing brand needs before committing to the cost of international trademark registration in the countries it sells into.
How does the six-month priority rule actually work?
Your first filing sets a date, and for six months you can file the same mark in other Paris Convention countries and claim that date. The easiest way I can describe it is a ticket at a deli counter.
When you file your first application, you take a numbered ticket with that day’s date on it. For the next six months, you can walk up to the counter in other countries and hand over that same ticket. Each of those offices treats you as if you had joined their queue on your original date, ahead of anybody who took a ticket after you. Once six months have passed, the ticket expires and you join each queue on the day you actually arrive.
The rule comes from the Paris Convention, which WIPO summarises as giving six months of priority for trademarks and designs (patents get twelve). In the UK it is written into section 35 of the Trade Marks Act 1994, which says three things worth knowing:
- The six months run from the date of the first application for the mark in a Convention country.
- The later application has to be for the same trademark, covering some or all of the same goods or services.
- If you file within the window, your first filing date becomes the date that decides who has the earlier right, and use of the mark in the UK in the meantime, by anyone, does not affect whether your mark can be registered.
One detail that surprises people: the first filing still gives rise to priority whatever happens to it later. The Act treats any filing that is adequate to establish a filing date as enough, even if that first application is later refused.
How does it work if you file in the UK first?
You file in the UK, then have six months to file abroad and claim your UK date. For most UK businesses the sequence looks like this, step by step.
- Search and clearance audit before the first filing. Everything that follows is built on this application. The mark you file and the goods and services you list are what you carry abroad, so it’s worth getting them right before the clock starts.
- File in the UK. This is the filing that starts the clock. The UK IPO’s official fee starts from £205 for one class. Official fees vary by territory and number of classes, and we confirm the exact figure before anything is filed.
- Diary the deadline. Six months from the filing date. File on 10 March and your window closes on 10 September. I’d put it in more than one calendar.
- Use the window to decide where you actually need protection. Which markets are you selling into, or likely to in the next year or two? The EU, where one EU trademark registration covers all 27 member states (EUIPO official fees from €850)? The US, somewhere else? This is also the time to run searches in those territories, because a clear UK register says nothing about Germany or Texas.
- File abroad and claim priority. The claim has to be made properly. In the UK, for example, an application claiming priority has to give the earlier application’s number, country and filing date, and other offices have their own versions of that paperwork.
My colleague Matt Griffiths put the budget case well on LinkedIn. Say you file in the UK today and, three months later, someone files something very similar at the EUIPO. Provided you file your own EU application within six months of your UK date and claim priority, your date comes first. The other applicant filed later than your priority date, not before it.
It works the other way round too. An overseas business can file at home and then come to the UK within six months claiming that date. The UK IPO’s examination guidance even deals with the situation where a UK application with a later filing date has already been published or registered by the time an international designation with an earlier priority date arrives. In that scenario, the international designation can still proceed. Being first to file in the UK is not always the same as being first.
If you’re using the Madrid system rather than filing country by country, an international application based on your UK filing can claim priority too. Our guide to whether the Madrid Protocol works for your brand covers when that route makes sense and when local filings are better.
What doesn’t the priority period do?
It doesn’t stop anyone else filing, beat rights that already existed, cover changes to your mark or stretch beyond six months. This is where misunderstandings tend to creep in, so it’s worth being clear about the limits.
It does not stop anyone filing
Nobody is prevented from filing a similar mark during your six months. What changes is whose date wins. If they file after your priority date, your application is treated as the earlier one.
It does not beat rights that already existed
Priority moves your date back to your first filing. It does not move it any earlier. If somebody in the EU filed a similar name before your UK application, priority won’t help you with them.
It does not let you change the mark
The later application has to be for the same trademark and for some or all of the same goods or services. If you refresh your logo in month four, or add a product range that wasn’t in the UK specification, the new elements don’t get the old date.
It cannot be stretched
Six months means six months. Miss it by a single day and you file as a normal applicant on the date you actually file. Nor can you keep refiling at home to restart the clock. The EU’s General Court rejected a strategy of successive national filings designed to do exactly that.
It is not something a company can give you
Priority comes from a filing at a trademark office, nowhere else. We’ve seen scam emails offering a “temporary filing priority” to pressure business owners into paying. No private company can grant that. If you get one of these emails, don’t pay anything until you’ve checked it.
What does this mean for a growing UK business?
It means your protection can keep up with your growth plans without paying for every country on day one. Those plans can change a lot in six months: a product that was UK-only in spring can have a European distributor by autumn.
But it only works if the first filing is right. Every application you file abroad inside the window leans on that first one, so it deserves the most care: a mark that is clear on the register, the right classes, and a specification that fits where the business is heading rather than only where it is today.
If international expansion is anywhere on your horizon, I’d think about it before the UK trademark application goes in, not after. Our UK filings start with a pre-application clearance audit, so the mark and specification you carry abroad have been checked first. That’s when we can help you plan protection in the countries that matter and set the six-month deadline against your actual launch dates.
A good first step is our free trademark search, which shows you whether the name looks clear in the UK. If you’re already thinking about the EU, the US or further afield, book a free call with our team, ring us on 0161 833 5400 or email enquiries@thetrademarkhelpline.com, and we’ll walk you through where priority can save you time and money.
Related questions
- Someone in another country is using my brand. Can I stop them?
- Do I need a trademark to sell on Amazon in the US or abroad?
- Can I register a trademark myself, or do I need an attorney?
This article is for information purposes only and does not constitute trademark advice or guidance. Last reviewed 25 September 2026. First shared as a LinkedIn post.
