How does copyright differ between countries?
Different countries have different copyright laws.
However, there are several international agreements that provide standards, including the first international agreement, known as the Berne Convention for the Protection of Literary and Artistic Works, which was first established in 1886 and set the tone for all later international agreements on copyright and related rights. This convention was last amended in 1971.
The Berne Convention sets out minimum standards of national copyright legislation (e.g. automatic copyright protection) in that each signatory country agrees to certain basic rules that their national laws must contain. Signatories should give citizens of other signatory countries the same rights of copyright that the convention gives to a country’s own citizens.
The World Intellectual Property Organization (WIPO) governs copyright and other intellectual property rights. Countries seeking membership of the World Trade Organization must also sign the Berne Convention.
The following countries in Africa are part of the Berne Convention:
Algeria, Botswana, Burkina Faso, Cameroon, Central African Republic, Chad, Comoros, Congo, Cote d’Ivoire, Democratic Republic of Congo, Egypt, Gabon, Gambia, Ghana, Guinea, Guinea-Bissau, Kenya, Lesotho, Liberia, Libya, Madagascar, Malawi, Mauritius, Morocco, Namibia, Niger, Nigeria, Rwanda, Senegal, South Africa, Sudan, Swaziland, Tanzania, Togo, Tunisia, Zambia and Zimbabwe.
Ratifications of the Convention (blue), Own work. Derived from File:Berne Convention.png by Conscious, released under GFDL/CC-BY-SA-3.0. Map derived from BlankMap-World6.svg by Canuckguy, released under PD-self.
Other countries in Africa have developed their own copyright laws, which may or may not include the same set of minimum standards as those dictated in the Berne Convention.
How long does copyright last?
Copyright duration differs between countries, lasting between 50 and 100 years after the author’s death, or for a shorter period for anonymous or corporate authorship. Thereafter, the copyrights of a work expire and the work becomes part of what is known as the ‘public domain’.
In the public domain, works are not copyrighted and are therefore freely available. Works that are in the public domain can be accessed and used freely and for any purpose – e.g. printed, copied, displayed, distributed, performed, modified or sold – without a licence.