Trademark Filing in Multiple ASEAN Countries: What You Actually Need to Know

If you’re thinking about trademark filing in multiple ASEAN countries, chances are you’re not looking for theory.
What you really want to know is simple, how do you keep your brand protected when your business operates across several ASEAN countries?

The answer is also simple—yet often overlooked:
ASEAN is one region, but it is not one trademark system.

ASEAN Is Regional, but Trademark Law Is Still National

ASEAN is often talked about as a single market, but when it comes to trademarks, each country applies its own national laws.
Indonesia, Singapore, Malaysia, Thailand, and Vietnam all have their own registration systems.

In practical terms:

• a trademark registered in Indonesia is not automatically protected in other ASEAN countries

• if you want protection in multiple countries, you need a cross-border filing strategy from the start

That’s why trademark filing in multiple ASEAN countries cannot be handled casually—especially not after the business is already up and running.

Madrid Protocol Helps, but Don’t Misread Its Role

Since Indonesia joined the Madrid Protocol in 2018, foreign brands have been able to file one international application and designate several ASEAN countries at once. From a procedural standpoint, this is clearly more practical and cost-efficient.

But there’s one key point you need to understand:
The Madrid Protocol simplifies filing. It does not unify trademark laws.

Research by Daniati et al. (2024) shows that the implementation of the Madrid Protocol in Indonesia still faces challenges, particularly in terms of policy standards, inter-agency coordination, and system readiness.
So even if the filing goes through a single channel, the final outcome is still determined by each country’s national law.

This is where many brands place the wrong expectations.

The Most Common Risk: First-to-File

Most ASEAN countries, including Indonesia, apply the first-to-file principle.
Whoever registers the trademark first is recognized as the legal owner.

The problem is that many foreign brands:

• assume they already “own” the brand globally,

• delay registration in certain ASEAN countries,

• and are caught off guard when the same mark has already been registered by someone else.

Data from the Indonesian Directorate General of Intellectual Property, as discussed in the referenced study, also shows that Indonesia is far more often a destination country for foreign trademark filings. This significantly increases the risk of overlapping trademarks and cross-border disputes within ASEAN.

Get the filing order wrong, and regional expansion can quickly turn into a legal conflict.

Relevant Legal Framework (If Indonesia Is One of Your Target Markets)

If Indonesia is among your ASEAN target countries, these are key legal instruments you should be aware of from the outset:

• Law No. 20 of 2016 on Trademarks and Geographical Indications

• Government Regulation No. 22 of 2018 on International Trademark Registration under the Madrid Protocol

• Presidential Regulation No. 92 of 2017 on Indonesia’s accession to the Madrid Protocol

These regulations govern international trademark registration and protection in Indonesia, but they do not eliminate differences between ASEAN countries’ trademark systems.

How to Approach Trademark Filing Across ASEAN

Trademark filing in multiple ASEAN countries is not about registering your mark everywhere.
It’s about registering in the right countries, in the right order, and at the right time.

Without a clear strategy, the risk isn’t just rejection—it’s losing trademark rights in another ASEAN country altogether.
Handled properly from the start, trademark filing becomes a solid foundation for safe regional expansion.

And in a market as competitive as ASEAN, that’s not an optional extra—it’s a necessity.