UK Patent Drawing Requirements: 9 Critical Schedule 2 Rules

Practitioners who arrive at the UK Intellectual Property Office from a USPTO background usually expect a long, prescriptive drawing rule and go looking for the British equivalent of 37 CFR 1.84. It does not exist. The UK patent drawing requirements occupy roughly one page of Schedule 2 to the Patents Rules 2007, and on several points they are markedly more permissive than the American standard — shading is allowed, and so are photographs. That brevity is exactly why applicants trip over them. A rule you can read in two minutes is a rule nobody reads carefully.

Where the UK patent drawing requirements are actually written

There is no free-standing drawing rule in UK patent law. Section 14(2)(b) of the Patents Act 1977 requires the application to contain a specification with a description, claims, and any drawing referred to in the description or claims. The form those drawings must take is then pushed down into secondary legislation: rule 14 of the Patents Rules 2007 points at Schedule 2 to the Patents Rules 2007, which is titled simply “Formal and other requirements”.

Schedule 2 is divided into four parts. Part 1 applies to every document in the application. Part 2 applies to documents other than drawings and photographs. Part 3 is the one that matters here — “Requirements: drawings and photographs”, paragraphs 11 to 20A. Part 4 carries a handful of general obligations about references and terminology that bite on drawings as well. Anyone summarising the UK patent drawing requirements from Part 3 alone will miss two provisions in Part 1 and two more in Part 4.

The structure matters for a practical reason. Because drawings and photographs are governed by the same paragraphs, every requirement in Part 3 applies to a photograph exactly as it applies to a line drawing. That is a deliberate choice, made when the Patents (Amendment) (No. 2) Rules 2016 (SI 2016/892) came into force on 1 October 2016 and extended Parts 3 and 4 to photographs.

Sheet, frame and margin: the envelope you are drawing into

Three Part 1 paragraphs apply before you draw a single line. Paragraph 1 requires A4 matt white paper. Paragraph 2 requires the document to be free from tears, folds or similar damage, with contents suitable for reproduction. Paragraph 3 is the one that catches CAD exports: frames — lines surrounding matter — must not be used. A border drawn around a figure, or a title block ruled off with a box, breaches paragraph 3 even though the figure inside it is faultless.

Paragraph 11 then sets the margins around any drawing or photograph: at least 20mm at the top and left side, at least 15mm at the right side, and at least 10mm at the bottom. Note the asymmetry. The generous top-and-left margin exists because that is where the sheet is bound and scanned; the bottom margin is half that.

UK vs US margins at a glance. UK (Sch. 2 para. 11): 20mm top, 20mm left, 15mm right, 10mm bottom. USPTO (37 CFR 1.84(g)): 2.5cm top, 2.5cm left, 1.5cm right, 1.0cm bottom. The right and bottom margins are identical; the top and left are 5mm tighter in the UK. A sheet drawn to US margins always satisfies the UK rule, but not the reverse.

Paragraph 18 supplies the reproduction test that ties the whole scheme together: a drawing or photograph must be produced in such a manner that it would still be clear if it were reduced by linear reduction to two thirds of its original size. This is the same substantive standard the USPTO applies under 37 CFR 1.84(k) and the PCT applies under Rule 11.13, so a figure prepared properly for one office will normally survive all three. Our note on patent drawing scale works through how to run that test rather than eyeball it.

Black lines, shading and cross-hatching

Paragraph 15 is the substantive drawing rule, and it is two clauses long. Drawings must comprise black lines, and they may be shaded where the shading assists in representing the shape of a thing, provided that it does not obscure other elements of the drawing. Paragraph 16 adds that drawings may include cross-hatching to illustrate cross-sections.

The permission to shade is newer than most practitioners realise. Before 1 October 2016 the UK rules were materially stricter, and the 2016 amendment relaxed them specifically to allow shaded drawings. The conditional wording is doing real work, though. Shading is permitted where it assists in representing shape — decorative rendering, drop shadows, photorealistic gradients and ambient occlusion from a 3D render are not shading in this sense, and if they obscure other elements they breach the proviso in the same sentence.

There is a second trap in paragraph 15 for anyone filing the same figures at multiple offices: the requirement is for black lines, full stop. Schedule 2 contains no petition mechanism for colour, no fee, and no exception. Where the USPTO will accept colour drawings on petition with the fee set out in 37 CFR 1.17(h) under 37 CFR 1.84(a)(2), the UK route for a colour figure is simply to convert it to a compliant black-and-white rendering before filing. The comparative position is covered in our guides to patent drawing shading and colour patent drawings.

Photographs: permitted in the UK, exceptional at the USPTO

This is the single largest divergence between the two systems, and it runs the opposite way to what most people assume. Paragraph 20A of Schedule 2 provides that photographs must be black and white, clear and capable of direct reproduction. That is the whole test. There is no requirement to show that a photograph was necessary, no petition, and no fee — a black-and-white photograph that reproduces cleanly is simply an acceptable way of illustrating a UK application.

The USPTO position is far narrower. Under 37 CFR 1.84(b)(1) photographs are not ordinarily permitted in utility and design applications, and are accepted only where they are the only practicable medium for illustrating the claimed invention — the rule gives examples such as electrophoresis gels, in vivo imaging and tissue sections. A photograph that would pass without comment in Newport can draw an objection in Alexandria.

Two qualifications keep this from being a licence to photograph everything. First, paragraph 20A’s “capable of direct reproduction” is a real threshold, and a photograph must still clear the two-thirds reduction test in paragraph 18. Second, because Part 3 applies to photographs and drawings alike, a photograph must carry its reference characters in the same way a drawing does. Our discussion of photographs in patent applications sets out when the photograph is genuinely the better disclosure.

Numbering, lettering and what may appear on the sheet

Four paragraphs govern how a set of sheets is assembled, and they distinguish carefully between numbering the figures and numbering the pages. Paragraph 12 requires all drawings or photographs to be numbered consecutively in a single series. Paragraph 14 separately requires the pages containing them to be numbered consecutively in a single series. Paragraph 13 requires the drawings to begin on a new sheet of paper.

1. Figures run in one unbroken series across the whole application — not restarting per sheet (para. 12).
2. Sheets carry their own consecutive series (para. 14).
3. Drawings start on a fresh sheet, never continuing from the claims (para. 13).
4. Capital letters used in a drawing or photograph must be more than 3mm high (para. 20).
5. A scale or other reference for making measurement must be represented diagrammatically, not written as a ratio (para. 17).

Paragraph 20 deserves emphasis because its threshold is higher than the equivalent US figure. The UK requires capital letters in a drawing to exceed 3mm; 37 CFR 1.84(p)(3) requires numbers, letters and reference characters to measure at least 0.32cm — 3.2mm — in height. The numbers are close enough that a set lettered to the bare US minimum sits within a fraction of a millimetre of the UK floor, with no headroom for the reduction in paragraph 18.

Paragraph 19 prohibits a drawing or photograph from being included in the description, the claims, the abstract or the request for grant. Paragraph 21, in Part 4, closes the loop from the other direction: references must only be included in the drawing or photograph where they are mentioned in either the description or the claims. Paragraph 23 requires terminology and references to be consistent throughout. Together these make an unreferenced numeral a formal defect, which is the same discipline discussed in our guide to patent drawing reference numerals.

Design protection is a different regime entirely

Schedule 2 governs patent applications. A UK registered design is filed under the Registered Designs Act 1949 and is represented by illustrations of the design rather than by patent drawings, with its own practice on disclaimers and the use of broken lines to exclude matter from the claimed design.

The contrast with the United States is instructive, because US design practice keeps design drawings inside the patent drawing rules. 37 CFR 1.152 requires the design to be represented by a drawing complying with 37 CFR 1.84, with a sufficient number of views to constitute a complete disclosure of the appearance of the design, and provides that broken lines may be used to show visible environmental structure but may not be used to show hidden planes and surfaces that cannot be seen through opaque materials. Practitioners moving a design portfolio between the two systems should read our note on design patent drawing broken lines before reusing figures.

The European route into the UK, and the Rule 46 EPC trap

The UK remains a contracting state of the European Patent Convention. Leaving the European Union did not change that, because the EPC is not an EU instrument — so a European patent can still be granted and take effect in the UK. What the UK is not part of is the Unified Patent Court and the unitary patent, which it withdrew from in 2020. A European patent covering the UK is therefore a classic national validation, enforced before the Patents Court or the Intellectual Property Enterprise Court, not before the UPC.

That matters for drawings because a great deal of published guidance still tells applicants that EPO drawings are governed by Rule 46 EPC. Rule 46 EPC no longer exists. It was deleted with effect from 1 February 2023, together with Rule 49(3) to (12) EPC, as part of the EPO’s digital-transformation package; the form requirements moved into a Decision of the President published in the Official Journal so that they can be updated without amending the Implementing Regulations. Anyone drafting to a checklist that cites Rule 46 as live law is working from a rule that was repealed three years ago.

The practical consequence is a genuine divergence. Since 1 October 2025 the EPO accepts drawings filed electronically in colour or greyscale, provided they are contrast-rich and clear at 300 dpi. The UK patent drawing requirements have not followed: paragraph 15 still requires black lines. A colour figure that the EPO will now accept must still be converted before it is filed at Newport. Our guide to EPO colour patent drawings covers the EPO side in detail.

Reconciling one drawing set across the UKIPO, USPTO and EPO

Most applicants who file in the UK also file in the United States, at the EPO, or both, and maintaining separate figure sets for each is a standing source of error. The economical approach is to identify the parameters where the three regimes genuinely diverge, draw to the strictest value on each, and accept a small amount of over-engineering in exchange for one master set.

• Margins. Draw to the US figures — 2.5cm top and left, 1.5cm right, 1.0cm bottom (37 CFR 1.84(g)). These exceed the UK minima in paragraph 11 on every edge, so a US-compliant sheet is automatically UK-compliant.
• Frames. Prohibited on both sides. Paragraph 3 of Schedule 2 bars lines surrounding matter, and 37 CFR 1.84(g) requires that sheets not contain frames around the sight. Delete borders and ruled title blocks once, globally.
• Colour. The strictest regime is the UK, which permits black lines only. Keep the master set monochrome and treat EPO colour filing and a US colour petition as deliberate, file-specific departures rather than the default.
• Shading. Both offices permit it, on similar reasoning: paragraph 15 allows shading that assists in representing shape without obscuring other elements, and 37 CFR 1.84(m) positively encourages shading where it aids understanding. Render artefacts satisfy neither.
• Character height. The UK floor in paragraph 20 is capitals above 3mm; the US floor in 37 CFR 1.84(p)(3) is 0.32cm. Lettering at 4mm or above clears both with room to survive reduction.
• Scale. Never write a ratio. Paragraph 17 requires any scale to be represented diagrammatically, and 37 CFR 1.84(k) prohibits written indications such as “actual size”. A graphic scale bar is the portable answer.
• Photographs. The strictest regime is the US. If a photograph is genuinely the only practicable medium, it will pass everywhere; if it is merely convenient, it passes in the UK and draws an objection at the USPTO.

The one parameter that cannot be reconciled by drawing to the strictest value is the reduction test, because it is a performance standard rather than a number. Paragraph 18, 37 CFR 1.84(k) and PCT Rule 11.13 all ask the same question — does the figure survive being shrunk to two thirds — and the answer depends on how much detail you packed into the sheet. That test should be run once, on the busiest figure, before the set is committed to any of the three offices.

A pre-filing check against Schedule 2

Formalities objections at the UKIPO are cheap to fix and expensive in calendar time, because they consume a round of correspondence that sits on the critical path to search and publication. In practice the same handful of defects recur, and all of them are visible on a five-minute review of the sheets before filing.

• A frame or border around the figure, or a ruled title block — breaches para. 3.
• Margins measured to the drawing rather than to the sheet edge, leaving less than 20mm at top and left — para. 11.
• Greyscale gradients or render shadows carried over from a 3D model — para. 15.
• A written scale ratio such as “1:2” instead of a diagrammatic scale — para. 17.
• Figure numbers restarting on each sheet instead of running in one series — para. 12.
• Reference numerals on a figure that never appear in the description — para. 21.
• A colour photograph, or a photograph that will not reproduce cleanly — para. 20A.

The UKIPO’s own Manual of Patent Practice, section 14 sets out how examiners approach the application as a whole, and is the right place to check current office practice alongside the rules themselves. Where a set of figures has to satisfy the UK patent drawing requirements and 37 CFR 1.84 at the same time, drawing to the stricter of the two on every parameter is almost always cheaper than maintaining two sets.

If you would rather hand the formalities to someone who does this daily, our patent drawing services prepare figures to UKIPO, USPTO, EPO and PCT standards from sketches, CAD exports or prior-art figures, and our London team handles UK filings directly.

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