EU Design Filings Get More Flexible Ahead of REUD Phase II
With the 1 July 2026 Phase II start date approaching, EUIPO has issued transitional guidance on the EU design reform package, giving applicants a clearer route through the changeover in terminology, filing practice and procedural handling. The former registered Community design, commonly known as the RCD, will formally move into the new name and framework of the registered EU design, or REUD.
The most practical change is the removal of the Locarno class restriction for multiple design applications. Under the old approach, designs included in the same multiple application generally had to fall within the same Locarno class. Under the new framework, a company may place a watch in Class 10 and a bracelet in Class 11 within the same multiple application. For businesses managing wearables, accessories, packaging, digital interfaces and physical product shapes as one launch package, this is not a cosmetic reform. It can change filing lists, budget allocation and disclosure timing.
Multiple applications are moving closer to product portfolio management
The old class-based rule often forced companies to divide design filings in a way that did not match how products are actually developed or launched. A consumer product family may include a device body, a strap, a charging dock, retail packaging, a graphical interface and display accessories. Commercially, those designs may belong to one product campaign. Procedurally, they could sit in different Locarno classes.
Once the same-class restriction is removed, the multiple application becomes a more flexible portfolio tool. Applicants can group designs around a product line, a launch window or a coordinated market release, rather than allowing the classification table to make the first cut. That flexibility still has boundaries. EUIPO materials indicate that a multiple application remains subject to a maximum of 50 designs. The point is not unlimited bundling; it is smarter bundling.
The watch-and-bracelet example says more than it first appears
The example of watches and bracelets is useful because it reflects the way modern design portfolios are built. Smartwatch makers may file for the watch body, replaceable straps, decorative rings, charging accessories, packaging and interface elements. Jewellery and fashion brands may combine physical accessories with display structures, limited-edition packaging and connected digital elements. Under the old rule, those items were often split into separate filings even when they belonged to the same commercial release.
The new rule allows part of that work to be consolidated. It may reduce administrative friction, align filing strategy with product planning and make cost forecasting cleaner. But consolidation should not become automatic. Designs with different disclosure dates, different priority sources, separate ownership expectations or distinct licensing and enforcement paths may still be better filed separately. A multiple application is a useful basket only when the basket matches the business reality.
The transition risk is mixing old and new filing rhythms
The 1 July 2026 date is close enough that many design projects now in preparation will sit near the line between the two regimes. The easy mistake is to focus only on the effective date and forget the surrounding tasks: view finalisation, product naming, priority documents, fee planning and deferred publication strategy. Design filing may look formal compared with patent prosecution, but weak drawings, rushed view selection or unclear publication instructions can create problems that are difficult to repair later.
For bulk filings scheduled in the first half of 2026, applicants should decide case by case whether waiting for the new rules would produce real procedural value. For design series that need to cross Locarno classes, waiting may be efficient. For products about to be shown at trade fairs, launched online or disclosed to distributors, the filing date and novelty window may matter more than the convenience of a combined filing. There is no universal answer. The product calendar should lead the decision.
What companies should do before Phase II starts
The first task is not to rename RCD files as REUD files. It is to rebuild the design filing schedule. Companies should map planned EU filings by product line, launch batch, Locarno class, priority source, disclosure date and expected commercial ownership. A schedule built this way will be more useful under the new rules than a file list organised only by classification.
The next step is to identify which designs should travel together. Designs are usually stronger candidates for the same multiple application when they share the same applicant, representative, publication rhythm and likely future commercial treatment. They are weaker candidates when confidentiality needs differ, priority claims come from different sources, or business units may later transfer or license the designs separately.
The REUD terminology change will be visible, but the operational shift is deeper. EU design filing strategy is moving from classification-led administration toward portfolio-led grouping. Companies that clean up their design inventories before July will be better placed to use the new flexibility without creating procedural clutter of their own.
