When working with creative works—whether as a student, educator, researcher, or librarian—understanding copyright law is crucial. But what happens when content crosses borders? Unfortunately, there is no single international copyright law that covers all countries and all situations. Instead, each country has its own copyright laws, and international treaties help coordinate protections and obligations across jurisdictions.
This guide will help you navigate the basics of international copyright considerations: from understanding how your own country's laws interact with others', to key treaties like the Berne Convention, and the rights that creators retain across borders. Whether you’re using foreign content in your classroom, managing licenses across international teams, or teaching students abroad, this guide will help you identify core legal considerations.
There is a common misconception that a unified international copyright law exists. In reality, copyright protection is granted through national legislation. However, international copyright treaties and conventions help align protections by setting common standards.
Treaties do not override national law but require signatory countries to implement agreed-upon protections. This makes understanding your country’s copyright law critical, while also being aware of your country’s obligations under international agreements.
Copyright becomes international when content or users cross borders. Some common scenarios include:
Each scenario brings legal questions about what is permitted under both domestic and foreign copyright laws.
The Berne Convention for the Protection of Literary and Artistic Works is the cornerstone of international copyright law. Administered by the World Intellectual Property Organization (WIPO), the treaty includes nearly 200 member countries and sets minimum standards for copyright protection.
Moral rights protect the personal and reputational interests of creators, and are separate from economic rights like copying or licensing. These may include:
Civil law countries (e.g., France, Germany) provide strong moral rights protections. Common law countries (e.g., U.S., UK) generally offer narrower protections.
The U.S. implements limited moral rights through Section 106A of the Copyright Act, known as the Visual Artists Rights Act (VARA).
VARA offers narrower moral rights than those available in civil law countries.
The internet and global education make almost every copyright issue international. To manage these complexities:
| Treaty | Description | Link |
|---|---|---|
| WIPO Copyright Treaty (WCT) | Adapts Berne Convention principles for digital content | View Treaty |
| Marrakesh Treaty | Improves access to content for the blind and visually impaired | View PDF |
| Beijing Treaty | Grants rights to audiovisual performers | View Treaty |
| TRIPS Agreement (WTO) | Global minimum standards for IP under trade law | View Treaty |
| Geneva Phonograms Convention | Protects sound recordings internationally | View Treaty |
| Brussels Satellite Convention | Prevents unauthorized retransmissions of satellite broadcasts | View Treaty |
