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Trademarks abroad for skincare brands: the Madrid System and beyond

How to protect your brand name in the countries where you sell and make your products: Madrid, EU and national filings, which markets to file first, official costs, customs recordation and marketplace brand registries.

Not legal adviceTrademark law differs by country. Use this guide to plan, and have a trademark attorney check your filings, especially in China and wherever an office raises an objection.

Short answer

A trademark only protects you in the countries where it is registered, and most countries, including China and Korea, give the mark to whoever files first. After filing at home, you can extend the same mark to other member countries with one international application through WIPO's Madrid System, filed through your home office, in one language and with fees in Swiss francs (basic fee 653 Swiss francs, plus a fee per country), as of October 2026. For the first five years the international registration depends on your home filing, so a problem at home can cancel it everywhere. File first in the markets where you sell in the next two years, where you manufacture (Korea for K-beauty brands) and in China, mostly in class 3 and often class 35, and file within 6 months of your home filing to keep its priority date.

This guide assumes you have chosen a name and filed, or are about to file, at home. Searching, picking classes and filing in the US, UK and EU are covered in how to trademark a skincare brand name, and the wider name checks (domains, handles, marketplaces) in brand name checks.

Why file abroad, and why early

Trademarks are territorial. A US registration gives you no rights in Canada, the EU or Japan. Each market needs its own registration, or a regional one such as the EU trade mark.
Most of the world is first-to-file. In China, the rights go to whoever files first, regardless of who used the mark first, and the EU's China IP SME Helpdesk warns that trademark squatters and some importers register foreign brands to sell them back or block them. Korea and most other countries also grant rights by filing.
You are already visible abroad. A K-beauty brand is made in Korea, its packaging is printed in Korea, and its listings are public worldwide. A name that shows up on a marketplace or a trade fair can be filed by someone else in a market you have not reached yet.
Marketplaces and customs need a registration. Brand registries and customs enforcement work from registered (or sometimes pending) trademarks in that country.
The 6-month priority window. Under the Paris Convention, filings in other member countries within 6 months of your first filing can claim its date. Miss the window and anyone who files in between can get ahead of you.

How the Madrid System works

The Madrid System is run by WIPO (the World Intellectual Property Organization) under the Madrid Protocol. WIPO says it covers 133 countries through 117 members, as of October 2026. It does not create one worldwide trademark. It creates a bundle of national and regional rights from one application.

Have a basic mark.
You need an application or registration (the "basic mark") at a member office where you are a national, are domiciled or have a real business. For a US company that is the USPTO; for a UK company the UK IPO; for an EU company the EUIPO or a national office.
File through your office of origin.
You file the international application through that office, often online, in English, French or Spanish depending on the office. The goods and services cannot be wider than in your basic mark. The office certifies it and sends it to WIPO; WIPO also offers eMadrid for filing and managing portfolios.
Designate countries.
You choose the members where you want protection ("designations"), for example the US, the EU, the UK, China, Japan, Korea, Australia. You can add more later with a subsequent designation.
Pay in Swiss francs.
A basic fee (653 Swiss francs, or 903 for a mark in color, as of October 2026) plus a fee for each designated member. Some members charge an individual fee that can be much higher than the standard one. WIPO's fee calculator gives the exact total.
WIPO checks formalities and records the mark.
The international registration is published in the WIPO Gazette and sent to each designated office.
Each office examines it under its own law.
Each office can refuse protection, usually within 12 months, or 18 months for some members. A refusal is answered locally, usually through a local attorney. Without a refusal, the mark is protected there as if filed nationally.
Manage it centrally.
Renewals (every 10 years), changes of owner and address go through WIPO once for all designations.

Two practical details for US designations: the USPTO requires a declaration of bona fide intention to use the mark in the US with the designation, and if it raises an objection, a foreign-domiciled owner normally needs a US-licensed attorney to respond.

Dependency and central attack

For five years from the date of the international registration, it depends on your basic mark (Article 6 of the Madrid Protocol). If the basic mark is refused, withdrawn or cancelled in that period, in whole or in part, the international registration is cancelled to the same extent in every designated country.

Competitors know this. A central attack is an opposition or cancellation action against your basic mark at home, aimed at taking down all your Madrid designations at once. To reduce the risk:

Base your Madrid filing on a strong, well-searched basic mark, ideally one that is already registered.
Keep the goods list of the basic mark accurate, because narrowing it at home narrows everything abroad.
If the basic mark falls, use transformation: within 3 months you can file national or regional applications in the designated countries that keep the international registration's date (Article 9quinquies). You pay national fees again, but you keep your place in the queue.

After five years, each designation stands on its own.

Madrid vs EUIPO vs national filings

Route	How it works	Good for	Watch for
Madrid international registration	One application through your home office, many designations	Several countries at once, central renewals and changes	Dependency for 5 years; goods limited to your basic mark; some countries need local answers to objections
EU trade mark (EUIPO)	One registration for all EU member states, filed directly or designated through Madrid	Selling anywhere in the EU	One successful opposition in any member state can block the whole EU mark
National filing	Filed directly at each country's office, often through a local attorney	Markets outside Madrid, local-script marks, tailored goods lists, China	Separate fees, languages and renewals per country

Many brands mix routes: a home filing, then Madrid for the main markets including the EU, plus direct national filings in China for the Chinese-character version of the brand. EUIPO's official fee for an EU trade mark filed online is EUR 850 for one class, EUR 50 for the second and EUR 150 for each class from the third, as of October 2026.

Which markets to file first

Where you will sell in the next two years.
Your home market, then every country on your launch plan, including marketplaces you will list on (Amazon stores, TikTok Shop regions).
Where your product is made.
For a brand made in Korea, a Korean filing stops a local party from registering your name where your labels and boxes are printed and your goods are exported from.
China, even if you do not sell there yet.
Squatting is common, and a registered squatter can complicate exports, cross-border sales and future entry. File the Latin-script mark and decide on a Chinese-character name early.
Markets where counterfeits appear.
Large marketplaces and markets with known counterfeit trade in beauty products. Customs action there needs a registration.
Distributor markets.
Register before you sign a distributor, and in your company's name, not the distributor's; see wholesale and distributors.

Example planA US brand launching a Korean-made serum line on its own store and Amazon US, with Canada, the UK and the EU next year: file at the USPTO in class 3 (and 35), then within 6 months file a Madrid application designating Canada, the UK, the EU, Korea and China, and add Australia or Japan later as a subsequent designation when those launches are planned.

Classes, local scripts and China

Class 3 covers non-medicated cosmetics and toiletries: the core class for skincare. Class 35 covers retail and online store services and is useful once you run a store. Medicated products and supplements can fall in class 5, and salons and clinics in class 44. The class headings are in WIPO's Nice Classification.
Local scripts. In China, the China IP SME Helpdesk advises registering the English name, the Chinese-character name and the pinyin version. Japan (katakana) and Korea (Hangul) are worth considering where shoppers will call your brand by a local version.
China's subclasses. The Chinese office examines similar goods by subclasses within each class, so the goods you list matter more than in many other countries. A China-experienced attorney is worth the fee there.
Beware of fake renewal and registry letters. WIPO warns about requests for payment from organizations that imitate official notices. Pay fees only to WIPO, your trademark office or your attorney.

Timelines and official costs

Item	Official figure (as of October 2026)	Source
Madrid basic fee	653 Swiss francs (903 for a mark in color), plus a fee per designated member	WIPO; exact total from the WIPO fee calculator
Madrid refusal period	12 months, or 18 months for some members, from notification of the designation	WIPO Madrid FAQ
Dependency period	5 years from the international registration date	Madrid Protocol, Article 6
Priority window	6 months from your first filing	Paris Convention, Article 4
EU trade mark, online	EUR 850 for 1 class, EUR 50 for the 2nd, EUR 150 each from the 3rd	EUIPO
US application	$350 per class at the USPTO	USPTO fee schedule
US customs recordation	$190 per class	19 CFR 133.3, CBP e-Recordation
EU customs application for action	Free	EUIPO IP Enforcement Portal

Attorney fees come on top and vary widely. A realistic plan for a first international filing is a home filing at launch, a Madrid application within 6 months, and most designations decided 12 to 18 months after that. Fit it into your launch timeline; see the 90-day launch playbook.

Customs recordation: US CBP and EU applications for action

A registration lets you sue. Recording it with customs lets officers stop counterfeits at the border.

United States. Owners of trademarks registered on the USPTO's Principal Register can record them with CBP through the e-Recordation system (IPRR). The fee is $190 per class under 19 CFR 133.3. CBP then uses the recordation to detain and seize infringing imports. Add product photos and a guide to telling real from fake.
European Union. Rights holders file an application for action (AFA) asking customs to detain suspected infringing goods. Since October 3, 2024, AFAs must be filed electronically, through the EUIPO's IP Enforcement Portal (or the national portals of Germany and Spain). Filing is free, an AFA is valid for 1 year and can be extended, and the applicant needs an EORI number. A Union AFA, based on an EU-wide right such as an EU trade mark, covers several member states at once.
Other markets. The UK, Japan, Korea, China and many others run their own customs recordation systems. Ask your attorney in each market.

Marketplace brand registries

Amazon Brand Registry accepts a registered trademark, or a pending application, from the trademark office of a country where Amazon has a store, and gives you tools to report counterfeits and control listings. Each Amazon region checks marks from its own eligible offices, so a US mark alone does not cover every store.
Walmart and TikTok Shop run their own brand and IP protection programs for rights owners, based on registered trademarks.
Keep the records consistent. The same company name should own the trademark, the barcodes (GS1) and the marketplace account; see barcodes for skincare.

For marketplace launches in detail, see selling skincare on Amazon and TikTok Shop.

Common mistakes

Filing only at home and assuming it protects you abroad.
Missing the 6-month priority window and losing your filing date abroad.
Basing a Madrid filing on a weak home application that a competitor can attack, taking all designations with it.
Skipping China and Korea because you do not sell there yet.
Letting a distributor or agent file your trademark in its own name.
Forgetting a Chinese-character version of the brand.
Paying "renewal" or "registry" invoices from organizations that are not WIPO, your office or your attorney.
Not recording registered marks with customs in markets where counterfeits appear.

Checklist

Home filing made in your company's name, in class 3 (and 35 if you run a store)
Date of the 6-month priority deadline in your calendar
List of markets for the next two years, plus Korea and China
Searches done in each target market (WIPO Global Brand Database, TMview, national registers)
Madrid application filed through your home office, or national filings planned
EU covered by an EU trade mark or a Madrid designation of the EU
Chinese-character name chosen and filed if you may sell in China
Local attorney contacts for answering refusals
US mark recorded with CBP once registered
EU application for action filed once registered
Brand registries enrolled on each marketplace
Renewal dates tracked, and only official invoices paid

How KoreanOEM helps

Your brand belongs to you. We make the product under it and keep everything about it in your name.

Your name, filed by you. You choose and file the trademark in your own company's name; we print it on the label and box from your artwork.
A custom formula developed for your brand is not offered to other brands, and NDAs are available on request, with a mutual NDA you can sign online in My page; see formula ownership and NDAs.
Labels checked for each market through our label proof check before printing, including the importer or responsible person details that sit next to your brand.
Documents marketplaces and importers ask for: COA, SDS, specification, a copy of the ISO 22716 certificate and, where needed, a Certificate of Free Sale (USD 100 per certificate for up to 10 products).

Get a free quote Open the brand starter kit

Frequently asked questions

Does my US or UK trademark protect my brand in other countries?

No. Trademarks are territorial, so each country or region needs its own registration. The Madrid System lets you extend a home filing to other member countries with one international application, but each designated country still examines and grants it separately.

How much does a Madrid international trademark cost?

As of October 2026, WIPO's basic fee is 653 Swiss francs, or 903 for a mark in color, plus a fee for each designated country, and some countries charge much higher individual fees. WIPO's online fee calculator gives the exact total; attorney fees are extra.

What is central attack in the Madrid System?

For five years the international registration depends on your home filing, so if a competitor gets the home mark refused or cancelled, every designation falls with it. You can then transform the designations into national applications within 3 months and keep the original date.

Should I register my skincare trademark in China?

Usually yes, if you may ever sell there or want to protect a brand made in Asia. China gives the mark to whoever files first, and squatters and some importers register foreign brands, so file early and consider a Chinese-character version too.

Do I need a trademark in Korea if my products are made there?

It is worth considering. Korea is a first-to-file country, and your labels, boxes and export documents are produced there, so a Korean registration stops a local party from claiming your name in the market your goods ship from.

Is it better to file an EU trade mark directly or through Madrid?

Both give an EU-wide right. Filing directly at the EUIPO avoids Madrid's five-year dependency on your home mark, while a Madrid designation of the EU is simpler if you are designating several countries at once; as of October 2026 a direct online EU filing costs EUR 850 for one class.

How do I stop counterfeit skincare at the border?

Record your registered trademark with customs: in the US through CBP's e-Recordation system at $190 per class, and in the EU with an application for action through the EUIPO's IP Enforcement Portal, which is free and valid for one year at a time.

Which trademark classes does a skincare brand need abroad?

Class 3 for cosmetics and skincare is the core, and many brands add class 35 for retail and online store services. In China, list the goods carefully because the office examines by subclasses.

Sources

Checked against these sources in October 2026. Rules and fees change; check with the authority or your importer before you sell.