International copyright protection
Although details of national laws may differ, the basic rights are the same in most countries due to international conventions and agreements (principally the Berne Convention) that provide a common framework that national legislation must follow to ensure countries respect the rights of foreign authors.
This means that copyright automatically protects your work at a worldwide level.
Principal conventions and agreements
1. The Berne Convention
179
countries covered
under Berne Convention
The Berne Convention is the main international convention governing copyright. It lays down the common framework: rights of the author, minimum guaranteed copyright duration, actions requiring permission, etc. that all contracting states must incorporate in their national laws and extend to foreign artists and authors.
As of November 2020 there are 179 countries that are signatories of the Berne Convention (source: World Intellectual Property Organization).
For more information, please see our main article on the Berne Convention.
2. TRIPS
164
countries are
WTO members
Agreement on Trade-Related Aspects of Intellectual Property Rights (or TRIPS for short) is an agreement between all the member nations of the World Trade Organization (WTO).
From a copyright perspective much of the provisions are the same as the Berne Convention. A full description of the agreement can be found on the WTO website.
From July 2016, the WTO had 164 members and 23 observers (source: www.wto.org).
Other treaties and agreements
There are additional treaties that convey additional rights or have historical significance, these are:
- The WIPO Copyright Treaty (WCT)
a special agreement under the Berne Convention which deals with the protection of works and the rights of their authors in the digital environment.
-
Marrakesh Treaty
The "Marrakesh Treaty to Facilitate Access to Published Works for Persons Who Are Blind, Visually Impaired, or Otherwise Print Disabled (2013)", allows for government authorised entities to reproduce and distribute accessible verisons of books to people that are blind, or have a visual impairment or other disability that impairs their ability to read a book. - Universal Copyright Convention (UCC)
Now of little significance as all UCC members are now also members of the Berne Convention or TRIPS. For more information, please see our main article on the Universal Copyright Convention (UCC).
In addition to the above treaties, countries may have unilateral deals with other countries directly.
Non-signatory countries
There are only a handful of countries that are not signatories of either TRIPs or the Berne Convention these are:
- East Timor
- (observer of UCC Paris), - Eritrea
- (has provisions covering copyright works in the Provisional Commercial Code of Eritrea and Provisional Civil Code of Eritrea of 1993), - Ethiopia
- (observer of TRIPS), - Iran
- (observer of TRIPS), - Iraq
- (observer of TRIPS), - Marshall Islands
- (signatory of WIPO Convention), - Palau
- (has provision covering copyright under the Republic of Palau Copyright Act of 2003 ), - Somalia
- (observer of WCT), - South Sudan
- (observer of TRIPS),
All other countries are signatories of the Berne Convention or TRIPS.
Copyright registration
Using evidence submitted to our service internationally.
In a ownership dispute you can call on us to produce a copy of work you have lodged with us as independent evidence of the exact content of your work as it existed at the point of registration (our 'duplicate work' service). This evidence can then be presented to the judge, tribunal, etc. hearing the case to help establish your prior claim on the work.
It should make little difference where a case is brought, or the evidence is used; evidence is still evidence.
To that end, we place no restriction on how or where you use the evidence we provide.
For most of our clients a single registration of their work with us is all they require.
Notes & further resources
US Citizens only:
The USA is a bit out of step in its domestic policy, so there are a few considerations you should read if you are a US Citizen
Up to date list of convention signatories:
An up to date list of signatory countries to the various international copyright agreements is maintained at wikipedia.org