Registering a trademark in multiple countries? Read this before using WIPO

The World Intellectual Property Organization (WIPO) is a specialized agency of the United Nations responsible for promoting and protecting intellectual property worldwide through cooperation among countries.

One of WIPO’s key tools is the Madrid System, which includes two main treaties:

Most countries today participate under the Madrid Protocol, which allows businesses to file a single application (called an international application) to seek trademark protection in multiple countries (called designated Contracting Parties). As of mid-2025, more than 130 countries are members, including the U.S., EU member states, China, Japan, Australia, and many others.

At its core, WIPO simplifies international trademark registration. Instead of filing separate national applications in each country, you file one “international application” based on your existing registration (or application) in your home country, also known as the Office of Origin.

Once approved by WIPO, your application is forwarded to the trademark offices in each country you’ve selected (called designated Contracting Parties). Those offices then conduct their own local examination. If no objections are raised, your trademark is protected as if it had been registered directly.

Despite its many advantages, the Madrid System is not a perfect fit for every business. Here are some critical caveats to consider:

One of the most significant risk when it comes to filing through WIPO is the so-called “central attack” vulnerability. For the first five years, your international registration is dependent on your base (home) registration. If your home application or registration is canceled, limited, or refused for any reason, your entire international registration can be affected.

If this happens, you must convert your international application into national applications (a process called transformation)—which is expensive and time-consuming.

Each designated country will examine your trademark under its own laws. This means a mark accepted in your home country may be refused elsewhere due to differences in descriptiveness standards, conflicting marks, or prohibited terms. Additionally, you might face opposition proceedings or office actions in some countries and not in others.

While WIPO promotes itself as a cost-effective solution, there’s a base fee (653 CHF) no matter how many countries you select. In most cases, this means that if you are planning to file a trademark in less than 4-5 countries, it will be cheaper to file directly through national trademark offices or through a global trademark service like Trama.

If a country’s trademark office issues an Office Action (which is a highly common scenario in the case of US), you’re required to hire a local attorney to respond. WIPO doesn’t help with this, leaving you to find and coordinate legal support on your own.

While WIPO offers a centralized route, it’s not always the best fit—especially for businesses targeting just a few countries or lacking legal support. In many cases, filing directly with national trademark offices can be simpler, more cost-effective, and legally safer.

For companies looking for more tailored trademark protection—especially when dealing with niche product descriptions or navigating legal challenges in individual countries—Trama provides tools and legal support aimed at simplifying the process while maintaining global reach.

Here’s a practical breakdown of these three options for effective international trademark registration: