EU Design Reform Phase II: What changes on 1 July 2026 — and how to prepare

Phase II of the EU Design Reform introduces substantial procedural changes. For those filing applications for EU design registrations, immediate strategic adjustments are essential.

While Phase I (May 2025) updated substantive law, Phase II puts those reforms into practice. Commission Implementing Regulation (EU) 2026/138 and Delegated Regulation (EU) 2026/137 both enter into force on 1 July 2026, giving the EUIPO the blueprint it needs to operate the modernized system. Here is what changes, and what it means for both applicants and professionals:

1. The end of the seven-view limit and acceptance of new types of representations

For years, EU design applicants were limited to seven static views; a constraint that made it nearly impossible to represent animated interfaces, multi-position products, or digital-first designs accurately. That hard cap is now abolished by the new Implementing Regulation. Whether the number of static views will still be limited, and the exact number of representations allowed, will be set by the EUIPO through their Design Guidelines to be published in July 2026.

In addition, the EUIPO will accept video files, CAD models, and computer-generated images alongside static representations.

In practice, this opens the door for consumer electronics brands to protect specific animated interactions, such as home screen animations, app transitions, software interfaces and dynamic dashboards.

2. Minor filing errors can now be fixed

Previously, correcting even a minor defect in a filed representation was notoriously difficult. The new rules allow applicants to amend an application or registration to fix "immaterial details" — a practical safety valve for the small inconsistencies that slip through before filing, without opening the door to wholesale redrafting of a weak application.

For years, EU design applicants were limited to seven static views; a constraint that made it nearly impossible to represent animated interfaces, multi-position products, or digital-first designs accurately. That hard cap is now abolished.

3. Invalidity challenges become more demanding - for everyone

Invalidity actions can no longer be filed as placeholders. Challengers must now submit a fully reasoned statement, with facts, evidence, and arguments, from day one. Weak or speculative attacks will be harder to sustain. But design holders face the same pressure: your evidence of prior use, first disclosure, and launch dates needs to be organized before a dispute starts, not during it.

4. Other procedural changes

• Priority claims extended from one to two months after filing.

• Missed deadlines: a new limited ability to continue proceedings has been introduced, similar to EU trademark practice.

• License cancellation fees removed; translations no longer need certification unless specifically requested.

• Time extension requests must now be formally reasoned.

July 2026 is closer than it looks. The businesses best positioned under the new system will be those that start adapting now, not after the rules are already in force.

If you have questions about how these changes, and the Phase I changes, affect your design portfolio or filing strategy, feel free to get in touch.

Disclaimer: This article is intended for general informational purposes only and does not constitute legal advice. The information provided reflects the state as of the date of publication and may be subject to change. Readers should not act on this information without seeking professional legal advice tailored to their specific circumstances. Saar Alon IP Law Firm accepts no liability for any loss or damage arising from reliance on the contents of this article.