Under the U.S. Copyright Act (Title 17 U.S.C.), the United States Copyright Office (USCO)
administers all copyright registration services via its online eCO system. In February 2026,
the newly launched Group Registration of Two-Dimensional Artwork (GR2D) program has
greatly simplified registration procedures for bulk visual works such as product images,
packaging designs and commercial illustrations. This reform aims to lower application costs
for creators and enterprises engaged in cross-border e-commerce and graphic design.
Combined with a typical compliance dispute, this article analyzes the eligibility rules,
common mistakes and practical risks of GR2D group registration, providing reliable guidance
for global visual content producers.
A cross-border e-commerce brand specializing in home goods created over 200 original
product photos and packaging patterns in 2025. To cut registration expenses and streamline
procedures, the company submitted a single GR2D group application to USCO, mixing
professional studio photos, simple text labels and public-domain basic geometric patterns.
The applicant believed all items were graphic works and qualified for group registration.
After examination, USCO rejected the application in early 2026. The official notice pointed
out two major defects. First, the application included non-copyrightable public-domain
patterns and purely descriptive text labels, which violated GR2D’s basic eligibility that
all grouped works must be original two-dimensional artworks. Second, the submitted
works covered multiple creation batches and different release periods, while GR2D requires
grouped works to be created or published within a reasonable unified timeframe.
The brand revised the materials by removing ineligible content, dividing works into two
qualified groups based on creation dates, and resubmitted the application. The revised
filings passed review and obtained official copyright certificates two months later. Later,
when similar imitative works appeared on competing stores, the company successfully initiated
infringement litigation with its valid group registration certificates as solid evidence.
First, strict eligibility applies to GR2D group registration. Only original two-dimensional
artworks including photographs, illustrations and packaging designs can be grouped. Public
domain elements, purely functional text and standard symbols are excluded. Mixed submission
will lead to overall rejection.
Second, unified creation and publication timeline is a mandatory rule. USCO sets clear
limits on the time span of grouped works to prevent enterprises from arbitrarily combining
works produced in different years for cost reduction. Applicants must classify files by creation
batches.
Third, group registration enjoys the same legal effect as individual registration. Certificates
from GR2D can be fully used for federal litigation, claiming statutory damages and
administrative enforcement, which is highly cost-effective for enterprises with massive visual
content.
Fourth, accurate work disclosure is required. When submitting deposit copies via the eCO
system, applicants must mark each independent work clearly. Vague cataloging will cause
obstacles during subsequent rights protection.
Classify works in advance before applying for GR2D. Sort out original visual artworks
separately and eliminate public domain or non-creative content to avoid overall rejection.
Divide bulk works into reasonable groups according to creation and publication time, strictly
following USCO’s timeline requirements for group registration.
Standardize file naming and cataloging when uploading materials on the eCO platform,
ensuring each work is distinguishable for future right confirmation.
Keep creation manuscripts, shooting records and design drafts. These materials can
cooperate with group registration certificates to form a complete evidence chain in
infringement cases.
Choose appropriate registration types rationally. For a small number of high-value artworks,
individual registration is recommended; for large batches of regular product images, GR2D is
the optimal choice.
The GR2D group registration rule launched by USCO in 2026 provides an efficient and
economical solution for enterprises with large quantities of two-dimensional artworks.
However, simplified procedures do not mean relaxed examination. This case proves that
violations of eligibility and timeline rules will directly result in application failure. For cross-border
e-commerce sellers, design studios and global visual creators, fully understanding GR2D
provisions, standardizing material sorting and submission is the key to obtaining stable
copyright protection, reducing IP costs and effectively safeguarding legitimate rights in the U.S.
market.
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