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Madrid Protocol vs EUTM: Which Route for the Turkish Exporter?
Madrid Protocol: a single filing across 127 countries. EUTM: a single filing across 27 EU states. Which is more advantageous for an exporter based in Türkiye? A decision matrix.
For overseas trademark registration, exporters based in Türkiye face two main routes: WIPO's Madrid Protocol or the EU's EUTM (EUIPO) system. The right choice depends on your target market, budget and risk tolerance. This article presents the decision matrix.
Comparison matrix
| Criterion | Madrid Protocol | EUTM (EUIPO) |
|---|---|---|
| Scope | 127 member states | 27 EU states |
| Filing point | From Türkiye (WIPO via TÜRKPATENT) | Directly with EUIPO Alicante |
| Base-mark requirement | Required (Turkish base mark) | Independent filing |
| Process duration | 12–24 months | 6–9 months |
| Single-filing cost | WIPO basic fee + country fees | EUR 850 (1 class) — lower |
| Registration certificate | Separate per country | Single certificate for EU |
| Renewal | Single WIPO renewal for all designations | Single EUTM renewal for EU |
| Risk: central attack | If the base mark is cancelled in the first 5 years, all international registrations fall | None |
| Risk: single opposition | Each country handles oppositions separately | A single EU opposition can take down all 27 |
Which is right for you?
Exporting only to the EU: EUTM. Faster, cheaper, single certificate.
EU + other continents (US, China, Japan, Australia): Madrid Protocol. You can also select EU members within Madrid.
EU + only 1–2 other countries: Hybrid — EUTM + direct national filings.
Speed-to-market pressure (within 1 year): EUTM (6–9 months). Madrid takes 12–24 months.
Base-mark cancellation risk (the Turkish registration is weak): EUTM, being an independent filing, has no central-attack risk.
Cost example — 5 EU countries
Madrid route:
- WIPO basic fee: 653 CHF
- Germany: 525 CHF
- France: 100 CHF
- Italy: 102 CHF
- Spain: 116 CHF
- Netherlands: 200 CHF
- Total:
1,696 CHF (₺57,000 + Asil attorney fee)
EUTM route:
- 1-class application: EUR 850
- Each additional class: EUR 50 (2nd class), EUR 150 (3+ classes)
- Single filing → 27 EU states
- Single-class total: EUR 850 (~₺30,000 + Asil attorney fee)
For 5 EU countries, EUTM is clearly more economical; moreover, the remaining 22 EU states come as a bonus.
What is "central attack" risk?
In the Madrid system, if your Turkish base mark is cancelled within the first 5 years (e.g. a third-party invalidity action succeeds), all linked international registrations also fall. After 5 years the dependency ends; the international registrations become independent.
This risk is:
- Low when your Turkish registration is resilient (prior use, reputation)
- High when its distinctiveness is weak
At Asil this risk is assessed during the initial file review.
Hybrid strategy
In practice, many large exporters use both routes:
- For the EU: EUTM
- For non-EU markets: Madrid (with EU member states removed from Madrid)
This combination delivers both the EU's single-certificate advantage and global coverage. This hybrid structure is common in our portfolio files.
State support — for both routes
The Ministry of Trade's Overseas Trademark Registration Support covers both Madrid and EUTM filings. Up to USD 50,000 per trademark (within annual limits) reimbursable.
Sources
- WIPO Madrid Protocol
- EUIPO Trade Mark Regulation (EU) 2017/1001
Author: Salih Aksebzeci · TÜRKPATENT Agent Registry No. 188 · Published: 2026-05-07