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With many businesses operating across borders post-Brexit, understanding the differences in intellectual property (IP) law between the UK and other countries has never been more important. In this episode of the Lawdit Solicitors Podcast, Ellis and Elisa take a comparative look at how IP is treated in the UK and France, providing essential insights for creators, entrepreneurs, and legal teams.
From copyright and trademarks to enforcement mechanisms and post-Brexit challenges, the episode highlights how businesses must adjust their IP strategies when dealing across jurisdictions.
Key Highlights:
- No copyright registration in the UK: UK copyright is automatic upon creation. In France, while it is also automatic, creators often choose to register works via systems like Soleau envelopes or through notaries for added proof.
- Trademark differences: In the UK, a registered trademark lasts 10 years and is renewable. France follows a similar timeline but has different application routes and enforcement traditions.
- Enforcement strategies: The UK has a more adversarial court system, while France favours administrative remedies first. This has implications for how IP disputes are pursued.
- Brexit impact: EU-wide IP protections no longer apply in the UK, so dual registration is now often necessary.
- International trading tip: Businesses expanding into France must adapt their contracts and protections accordingly—especially for IP-heavy industries like tech, music, and media.
