Trademark Wiki / 国际商标

Which Countries' Trademarks Must Cross-Border Sellers Register First?

Q&APublished 2026-09-17 · Updated 2026-09-17

First priority is the US, the EU and the UK; then Japan, Australia, Canada and others according to your marketplace footprint; defensive registration in Hong Kong and your manufacturing country is also recommended.

For cross-border sellers, the first-priority trademark registrations are the US, the EU and the UK (covering Amazon's main European and American marketplaces), followed by Japan, Australia, Canada, Singapore and others according to your actual marketplace footprint, with defensive registration in Hong Kong recommended in parallel.

Why Countries Are Chosen by Marketplace

Trademark registration follows sales: platform brand registry requires a registered trademark in the marketplace's jurisdiction, and customs recordation and hijacker enforcement also presuppose local registration. In markets without a registration, you have almost no recourse when listings are hijacked or complained against.

Recommended Priorities

Tier 1 (must-do)

  • United States: Amazon's largest marketplace; a hard requirement for Brand Registry and hijacker complaints;
  • European Union (EUTM): one registration covering 27 countries, usable across the German, French, Italian and Spanish stores — exceptional value;
  • United Kingdom: independent since Brexit and must be registered separately.

Tier 2 (do it if you have a marketplace there)

  • Japan: Rakuten and Amazon Japan; a large market with strict examination;
  • Australia, Canada, Singapore: all Madrid members and can be designated in a bundle.

Tier 3 (defensive layout)

  • Hong Kong: a hotspot for re-export and malicious complaints;
  • Manufacturing/OEM countries: prevents the OEM factory from squatting the mark and then complaining against your exports for infringement.

Save Money with a Combined Approach

For multi-country layouts, prefer a single Madrid application designating multiple countries — 30%–60% cheaper than engaging agents country by country. For the US, evaluate the filing basis (1a/1b/44e) separately and file directly on its own if necessary.

Common Misconceptions

  • Registering only in the US and assuming you are "safe worldwide";
  • Waiting until the product becomes a hit to register — squatters target exactly the hits, so applications should be filed six months before peak season;
  • Registering the store name instead of the brand name, wasting everything when the brand changes later.

In situations like this, it is advisable to consult a registered agent at MyTMBee first to assess whether a US trademark registration is needed before deciding on next steps.