The requirement to use a trademark

The requirement to use a trademark


Intellectual property is not just formalities, paperwork and entries in registers. Once you have secured your trademark, the real game begins: to keep your market advantage you must actually use the mark, not merely display a framed certificate on the wall. There are clear rules on when a brand owner has to prove that its mark is alive in the marketplace rather than lying dormant.

Below we explain what the obligation to use a registered trademark involves, when and how you must show use, the relevant deadlines and formalities, and what is at stake if you stay passive. You will find answers to practical questions here.

 

The requirement to use a trademark: key rules

 

Poland and the EU

After registration, both Polish law (the Industrial Property Law) and EU law require genuine use of the mark to begin within 5 years of the registration date and to continue without lengthy interruptions. A failure to make genuine use of the mark for a period of five years creates a risk of cancellationof the registration for those goods and services for which the mark is registered but not used.

A request for revocation may be filed by any person, and there is no need to provide a detailed justification. It is the trademark owner who must demonstrate use (the burden of proof).

NOTE: if the mark is registered to an individual (for example a company’s CEO) who does not use it himself, because only the company uses the mark, then a licence agreement should be put in place under which the trademark owner authorises the company to use the mark. Such an agreement, together with evidence of use by the company, allows the owner to show that the mark has been put to genuine use. Without a licence agreement, proving use by the owner can be difficult and in some cases even impossible.

 

China

China applies a “first to file” principle, and the obligation to use the mark arises only after registration. If a mark is not used in China for 3 consecutive years, any interested party may apply to have it cancelled. Use must be proven in a dedicated procedure that, on our clients’ behalf, has to be handled by an attorney from a local Chinese firm.

 

United States

The US system is based on the “first to use” principle: protection belongs to whoever first genuinely used the sign in commerce. When applying, you must submit an Intent to Use declaration or a Statement of Use, together with evidence of actual use of the mark in trade (specimens, photographs of packaging and labels).

  • Intent to Use (ITU) means having a genuine and documented intention to use the mark in commerce while actual use has not yet begun. On this basis an application may be filed (Section 1(b)) to “reserve” priority to the mark before it is launched on the market. No proof of use is required at this stage; a declaration of intent is enough.
  • Statement of Use (SOU) is a declaration confirming actual use of the mark in commerce. It is filed after a Notice of Allowance (NOA) is issued by the USPTO, within 6 months of receipt (extendable in 6-month periods up to a total of 3 years, although each extension carries a cost). The SOU is accompanied by supporting materials, such as photographs of products, packaging or service signage used in the US. Only after the SOU is filed can the mark proceed to final registration.
  • The cost of a Statement of Use is an official fee of around $100 per class of goods, plus the cost of handling the matter by a professional representative.
  • To maintain trademark protection in the US, the declaration of use must be renewed and continued use shown within the periods set by US law (Section 8 Declaration).

 

What counts as use of a trademark under Polish law?

The Industrial Property Law provides that the owner of a registered Polish trademark has the exclusive right to use it in a professional or commercial manner throughout Poland.

Use of a trademark consists in particular of:

  1. affixing the mark to goods or their packaging,
  2. offering and placing those goods on the market, exporting, importing and storing them,
  3. offering and providing services under the mark,
  4. affixing the mark to documents relating to the goods or services,
  5. using the mark in advertising or marketing.

 

Examples of trademark use

  • affixing the mark to goods or their packaging, for example a company logo on products (such as adidas clothing or Apple phones),
  • marking services with the sign on advertising materials, a website or invoices,
  • using the mark in marketing and promotional campaigns,
  • affixing the trademark to exported goods,
  • use of the mark by another business under a licence or franchise agreement,
  • using the mark in connection with offering or providing services, by placing it on advertising materials, offers, contracts, websites, invoices or promotional documents.

A trademark should be used in a form consistent with the registration, for the goods and/or services for which it is registered. Only minor modifications are permitted, provided they do not alter the essence of the mark and its distinctive elements.

Whether use of a mark in a modified version can be treated as use of the registered mark is decided by the UPRP and EUIPO on the basis of the Common Communication and Common Practice on the use of a trademark in a form differing from the one in which it was registered. That document contains a range of examples.

 

Who can challenge the validity of a mark for non-use, and when?

  • In Poland and the EU, anyone may file a request to cancel the protection right for a trademark on grounds of non-use over a period of 5 years, in whole or in part (that is, only for some goods and services).
  • In China, any party may do so after 3 years of non-use.
  • In the US, the situation is reversed: it is the trademark owner who, within the periods set by US law, must file a declaration of use (SOU) with the USPTO; otherwise the US office will cancel protection of the mark.

 

Trademark use in opposition and invalidity proceedings

Before the UPRP and EUIPO, during an opposition or invalidity dispute concerning a trademark, the office may, at the request of the opposing party, require the owner of the trademark on which the opposition or invalidity request is based to file evidence of genuine use for the goods and services covered by the proceedings, provided that at least 5 years have passed since the registration date of that mark.

It is worth stressing that a failure to file evidence in a given set of proceedings does not automatically cancel the registration. It affects only the current procedure: the opposition or invalidity request will be dismissed by the office for those goods and services for which the owner of the earlier mark has not shown genuine use.

 

Summary

The requirement to use a trademark is the foundation of its legal protection in Poland, the EU, the US and China alike. A failure to meet it can lead to cancellation of the mark’s protection, in part or in full. Whether you run an international brand or are a local business, entrust your trademark matters to an experienced trademark attorney from what you consider to be the best IP firm, so that you can be confident of effective protection and an optimal strategy for using your mark in business.

Our IP firm in Poznań will help you register your trademark and protect your brand. Write to us!

 

Frequently asked questions

When must I start using a registered trademark in Poland and the EU?

For both trademark registration in Poland and trademark registration in the EU, genuine use must begin within 5 years of the registration date and continue without lengthy interruptions. A continuous period of non-use of five years exposes the mark to cancellation for the goods and services for which it is registered but not used.

Who can challenge a trademark for non-use?

In Poland and the EU, any person may file a request for cancellation on grounds of non-use after five years, in whole or in part. The applicant does not need to provide detailed reasons; the burden of proof lies with the trademark owner, who must demonstrate genuine use.

What counts as genuine use of a trademark under Polish law?

Use includes affixing the mark to goods or their packaging, offering and placing those goods on the market, importing, exporting and storing them, offering or providing services under the mark, using the mark on business documents, and using it in advertising and marketing.

What happens if I do not file proof of use in opposition or invalidity proceedings?

Before the UPRP and EUIPO, failing to file proof of use does not automatically cancellation of the registration. It affects only the pending case: the opposition or invalidity request is dismissed for those goods and services for which the owner of the earlier mark has not shown genuine use.

Should I sign a licence agreement if the trademark is owned by an individual?

Yes. If a mark is registered to an individual (for example a company’s CEO) but is actually used by a company, a licence agreement authorising the company to use the mark should be in place. Together with evidence of use by the company, the agreement allows the owner to prove genuine use; without it, proving use may be difficult or impossible.

 

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