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A global look at copyright: How do countries set the duration of protection, and how many years can it be at most?
Copyright, as a legal right, gives creators the exclusive right to use their creations, covering a wide range of activities such as reproduction and publication. These actions include reproducing the work in electronic form, creating translations, producing television programs, and even uploading the work to the Internet. As long as it is a literary or artistic work, it is protected by copyright. It is particularly important to emphasize that copyright only protects specific forms of expression, not the creativity itself.
Collections of facts that are created may also be eligible for copyright protection if they involve creative activity.
According to the Berne Convention, the copyright protection period in various countries is usually set at the author's life plus at least 50 years. Certain categories of work, such as applied arts, are granted a 25-year term, and cinematographic works a 50-year term. Most countries have chosen to extend this protection period, especially in the EU and the US, where the life span is extended to 70 years. In addition, Mexico has extended this period to 100 years.
Copyright Law in the United States
Since the Berne Convention came into effect in the United States in 1989, American creators have automatically obtained copyright in their works without the need to register. However, much of the U.S. literature on copyright still continues to use the old registration principles, misleading readers. Nonetheless, copyright registrations still exist in the United States and are still required to bring lawsuits against infringers. This registration not only provides creators with a certain amount of legal protection, but also may enable them to obtain higher statutory compensation amounts.
Copyright Law in the European Union
As signatories to the Berne Convention, all countries within the European Union adhere to its provisions, and copyright-related provisions are also governed by European directives. Following the directive, these member states extended copyright protection to the author's life plus 70 years. Even more strikingly, this extension has a retroactive effect. This gives works that would otherwise enter the public domain 50 years after the author's death an additional 20 years of protection.
Under the Berne Convention, countries may not require any formal action to obtain copyright protection.
Overview of copyright duration in different countries
There are significant differences in the number of years that copyright protection lasts in different countries around the world. For example, under the Agreement on Trade-Related Aspects of Intellectual Property Rights (TRIPS), all member countries are required to set a minimum protection period of 50 years. In fact, different countries or regions are often influenced by their own culture, economy and legal framework when setting copyright terms. Therefore, the establishment of these standards and norms is not only related to the integration of internal laws, but also affects international intellectual property trade and exchanges.
Copyright protection in different countries has a profound and diverse impact on the creative industries.
After exploring the copyright laws of countries around the world, we can't help but wonder: In the digital age, how should copyright be adjusted in the future to better balance the relationship between creation and sharing?
