The UKIPO has taken Brexit in its stride, cloning several million EU trademark rights into UK rights. But more remains to be done. Since 1st January 2021 , the UK has been unilaterally participating in the EEA’s regional exhaustion regime. So  IP rights in goods first placed on the market in the European Economic Area (EEA) are considered exhausted in the UK. Allowing the goods to be imported into the UK without the right holders permission. Though the reverse does not apply due to the EES’s exhaustion regime.

There are a number of possible models, each offering advantages and disadvantages. But UK trademark rights, whether through a direct filing or inherited from EU rights, will continue to underpin the chosen system.