While most responses to the Circular supported the introduction of a new definition in the Administrative Instructions, some Member States questioned the practical necessity of introducing a new definition as summarized in below.

Support/Agree:

• As the option of submitting applications on paper still continues, introducing the Administrative Instructions a more detailed definition of what is understood by the term "signature" seems appropriate and gives greater flexibility to applicants.
• Work from home under the pandemic requires more flexibility for signing the paper document.
• There is no objection to support this proposal, since the modification is foreseen for the processing of the international phase, in addition to the fact that it will be similar to the provisions in force in the Administrative Instructions for the Application of the Protocol Relating to the Madrid Agreement Concerning the International Registration of Marks ("Madrid Protocol Administrative Instructions") and the Administrative Instructions for the Application of the Hague Agreement ("Hague Agreement Administrative Instructions").

Reservations:

• Some offices very seldomly receive documents on paper which requires multiple signatures.
• Somme offices, under its national law, require that the signature on documents submitted on paper must be autographed, and therefore, signatures in any other form are not allowed during the national phase.  The proposed amendment can be supported, as long as it refers to international phase procedure.
• Somme offices requested more clear definitions on the each type of "signature" (please view: discussion point 2.).
• A office showed concerns about the specific language that is being proposed (Please view: discussion point 3.).

Doubt:

• a office expressed doubt about the practical significance of this proposal in light of an increasing number of electronic filings.  Most applications filed on paper at this office are filed by individuals applicants who sign their applications themselves.