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Comparison of Copyrights Durations in Different Countries

Life + 25: The Universal Copyright Convention specifies that copyrights should run for the life of the author plus (at least) 25 years (which is sufficient to protect a work during the lifetime of the author and the minority of the author's children). Most UCC members, however, now have longer terms, because they have signed on to the Berne Convention, or have joined organizations like the World Trade Organization that require eventually implementing Berne's longer copyright terms. Some countries may still have the shorter UCC terms: Djibouti, Iraq, Libya, Sudan, etc.


Life + 30: In Iran and Yemen, copyrights tend to last for the lifetime of the author plus 30 years. Iran does not have copyright relations with the US or with international conventions, at last check, and Yemen's relations are unclear.

Life + 50: The Berne Convention specifies that copyrights should run the life of the author plus (at least) 50 years, rounded up to the end of the calendar year. "Life + 50 years", is therefore the standard copyright length in many countries, including (to the best of my knowledge) Algeria, Angola, Argentina, Armenia, Azerbaijan, Bahrain, Bangladesh, Barbados, Belarus, Belize, Bolivia, Benin, Brunei, Burkina Faso, Burundi, Cambodia, Cameroon, Canada, Chile, China, Cuba, the Dominican Republic, Egypt, El Salvador, Fiji, Ghana, Indonesia, Iraq (under US occupation rules), Japan, Jordan, Kazakhstan, Kenya, (South) Korea, Kuwait, the Kyrgyz Republic, Lebanon, Malawi, Malaysia, Moldova, Mongolia, Morocco, Namibia, Nepal, New Zealand, Niger, Oman, Pakistan, Panama, Papua New Guinea, the Philippines, Qatar, St. Vincent and the Grenadines, Saudi Arabia, Solomon Islands, South Africa, Syria, Taiwan, Tanzania, Thailand, Togo, Tonga, Trinidad and Tobago, Tunisia, the United Arab Emirates, Uruguay, Uzbekistan, Vietnam, and Zambia.


Life + 60: In India and Venezuela, copyrights tend to last for the lifetime of the author plus 60 years.

Life + 70: In the European Union, Albania, Andorra, Australia (for new works), Bosnia and Herzegovina, Brazil, Costa Rica, Croatia, Ecuador, Iceland, Israel, Liechtenstein, Macedonia, Madagascar, Nicaragua, Nigeria, Norway, Paraguay, Peru, Russia (for new works), Serbia and Montenegro, Singapore, Switzerland, Turkey, and Ukraine, copyrights tend to last for the lifetime of the author plus 70 years. (The European Union includes Austria, Belgium, Bulgaria, Cyprus, the Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, the Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, and the United Kingdom.) Life plus 70 years is also the standard duration of copyright in the United States for works first published after 1977.


Life+75: Even as more countries move to life+70 terms, some countries are now extending the copyright even further. These longer terms may in the future serve as an excuse for extensions in other countries in the name of "harmonization". In Guatemala, Honduras, and Samoa, for instance. copyrights tend to last for the lifetime of the author plus 75 years, with certain exceptions. I do not know if these laws cover older works or are just applied to copyrights current at the time the longer terms were adopted.

Life+80: In Colombia, copyrights tend to last for the lifetime of the author plus 80 years, with certain exceptions. Again, I don't know to what extent, if at all, this law retrospectively applies to older books, or whether they just apply to books under copyright when the longer terms were adopted.

Even longer: A few countries are now at or near the century point. In Cote d'Ivoire, copyrights tend to last for the lifetime of the author plus 99 years. And in July 2003, Mexico extended its copyrights to the lifetime of the author plus 100 years! Again, I don't know to what extent, if at all, these laws retrospectively apply to older books, or whether they just apply to books under copyright when the longer terms were adopted.

For more information, pls visit:

http://onlinebooks.library.upenn.edu/okbooks.html
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