1. EUTMs: Ensuring rights maintained in UK
Model
Timing
Unilateral or bilateral
Initial cost to business
UKIPO resource
Post-division conflicts
Legal certainty
EU plus
EUTM system becomes ETM system, covering EU & UK
Brexit
Bilateral
Low
High
Jersey
UK treats EUTMs as covering UK
Unilateral
Medium
Montenegro
EUTMs brought onto UK register as UKTMs
Brexit/ window
Medium-low
Tuvalu
Option to bring EUTMs onto UK register as UKTMs
Veto
Option to bring EUTMs onto UK register as UKTMs, but UKIPO retains veto
Medium-high
Ireland
Option to bring EUTMs onto UK register as UKTMs at renewal. EUTM covers UK in interim
At renewal/ long window
Conversion
Option to convert EUTMs into UK applications, with full examination as of filing date etc

2. RCDs: Ensuring rights maintained in UK
Model
Unilateral or bilateral
Cost to business
UKIPO resource
Post-division conflicts
Legal certainty
‘Decoupling’ – Community design system becomes European design system, covering UK + EU.
Bilateral
Low
High
‘Jersey’ – UK treats RCDs as covering UK.
Unilateral
Medium
‘Montenegro’ – RCDs brought onto UK register as UKRDs.
Medium [?]
Medium-Low
‘Tuvalu’ – option to bring RCDs onto UK register as UKRDs.
‘Veto’ – option to bring RCDs onto UK register as UKRDs, but UKIPO retains veto. [Note: Query relevance for registered designs given the very limited scope of pre-grant examination conducted by EUIPO/UKIPO]
Medium-High
Medium-High [Note: possibly 'low' due to limited examination requirements]
‘Conversion’ – option to convert RCDs into UKRD applications, with full examination as of filing date etc. [Note: given the very limited scope of pre-grant examination conducted by EUIPO/UKIPO, arguably no difference between this model and Veto little done on design exam so this would be same as Veto?]
[Note: possibly 'low' due to limited examination requirements]