As a content creator, it’s important to understand how copyright law works in different parts of the world. This is especially true if you plan to publish your works internationally or work with clients and partners from different countries. While copyright law shares some similarities across the globe, there are also many differences that can affect how you create, distribute, and protect your works. In this post, we’ll take a closer look at the differences and similarities between copyright law in the US, EU, UK, and other countries.
United States
In the US, copyright protection is granted automatically to original works of authorship fixed in a tangible medium of expression. This means that as soon as you create an original work, such as a book, song, or photograph, you automatically own the copyright to that work. However, if you want to enforce your rights in court, you need to register your work with the United States Copyright Office. The length of copyright protection in the US is generally the life of the author plus 70 years.
European Union
The EU has a harmonized copyright law system that applies to all member states. Under this system, copyright protection is granted to original works of authorship that are expressed in a tangible form. The length of copyright protection in the EU is generally the life of the author plus 70 years. However, the EU also allows member states to set their own copyright terms for certain types of works, such as photographs and audiovisual works.
United Kingdom
In the UK, copyright protection is also granted automatically to original works of authorship fixed in a tangible medium of expression. However, unlike in the US, there is no requirement to register your work with any government agency. The length of copyright protection in the UK is generally the life of the author plus 70 years.
Other Countries
Copyright law varies widely in other countries around the world. In some countries, copyright protection is granted automatically, while in others it must be registered. The length of copyright protection also varies widely, with some countries providing protection for as little as 25 years after the author’s death, while others provide protection for up to 100 years after the author’s death.
Some countries also have unique copyright laws that differ from those in the US, EU, or UK. For example, in Japan, copyright protection is granted for only 50 years after the author’s death, and in Canada, there is a special exception for “fair dealing” that allows certain types of copying and use of copyrighted works without permission.