Research Guides: Open Educational Resources: Non-U.S. Campuses

Copyright in other countries with ERAU Worldwide campuses

Copyright Law can vary depending on country. This page shows some of the countries where ERAU Worldwide campuses can be found and how their copyright laws compare to those in the U.S.

European Union

Copyright is automatically assigned to the author of the work when it is created.
Copyright guarantees economic and moral rights.
Copyright protects the work for 70 years after the authors death. In the case of a joint copyright, it will last until 70 years after the last author dies.
It is recommended to notify others of your copyright by using the © or stating "all rights reserved."
Copyright can be registered with a dedicated service provider.

For more information use the European Union official website.

As with in the U.S., Creative Commons is not a legally binding document and should be used in accordance with the EU and its member countries' copyright laws.

In 2019, the European Commission adopted the use of CC BY 4.0 and CC0 to allow for the public use and dissemination or their publications.

For more information on the European Commission's use of CC licenses, read their breakdown of the Creative Commons Attribution 4.0 International (CC-BY-4.0).

While the EU does not have a Fair Use equivalent, they do have exceptions to copyright protection detailed in the InfoSoc Directive of 2001, or the Directive 2001/29/EC.

To see a list of the exceptions and how they apply to each country, check out this handy map.

Category	European Union	United States
General Duration*	Life of author + 70 years after death	Life of author + 70 years after death
Berne Convention	Signed on	Signed on
Exemption for Education*	Yes	Yes, Fair Use
Registration	Automatic	Automatic

*Some exemptions and specifics exist. Please refer to the corresponding tab for more detailed information.

Japan

Works qualify for copyright protection if:
- the work is by a Japanese national
- the work was first published in Japan
- Japan is under obligation to protect a work in cooperation with an international treaty (such as the Berne Convention).
Copyright is automatic (some exceptions for anonymous works).
A work is under copyright protection for 70 years after the death of the author--for joint works, after the death of the last surviving co-author.
Moral and economic rights.

For a detailed list of rights, read the this online textbook from the Copyright Research and Information Center in Japan: Copyright Law of Japan, 2023.

As with in the U.S., Creative Commons is not a legally binding document and should be used in accordance with Japan's copyright laws.

Although Creative Commons previously had deeds available for Japan, specifically, the Attribution 4.0 International license is now recommended for use there. To read more about this license, check out CC's relevant legal code and the Attribution 4.0 International deed. Available in Japanese.

Japan does not have a "fair use" equivalent but offers some exceptions:

reproduction in libraries and similar facilities
printing of public works in textbooks
broadcasting of educational programming for schools
reproduction in schools and other educational institutions
reproduction for persons with visual and vision-related impairments
reproduction for persons with hearing impairments
stage performances for non-commercial purposes
reporting of current events

For more details, read Chapter 2, Section 2, Subsection 5: Limitations of Copyright in the Copyright Research and Information Center's Copyright of Japan textbook.

Category	Japan	United States
General Duration	Life of author + 70 years after death	Life of author + 70 years after death
Berne Convention	Signed on	Signed on
Exemption for Education	Yes	Yes, Fair Use
Registration	Automatic	Automatic

*Some exemptions and specifics exist. Please refer to the corresponding tab for more detailed information.

Singapore

Copyright is automatically assigned to the author of the work when it is created. Or, if the work is created in the course of work for an employer, the employer is the default owner. (This can be applicable in other countries depending on the employer's policy, however Singapore sets it as a default.)
The author retains copyright of a work even if it is commissioned. The commissioning party would need to negotiate for the transfer of copyright ownership.
Any sharing of copyrighted work MUST identify the original creator and any performers appearing in a performed work. Some exceptions apply.
Generally, copyright protects works of known authors for 70 years after the death of the author.
Films and anonymous or pseudonymous works will be protected for 70 years after the work was created or first released to the public.
There are some differences in copyright protection depending on the work.

For more details and a table breaking down the copyright variances for different types of works, read the Factsheet on Copyright Act 2021.

As with in the U.S., Creative Commons is not a legally binding document and should be used in accordance with Singapore's copyright laws.

Although Creative Commons previously had deeds available for Singapore, specifically, the Attribution 4.0 International license is now recommended for use there. To read more about this license, check out CC's relevant legal code and the Attribution 4.0 International deed.

Singapore does recognized some copyright exceptions referred to as "fair dealing" exceptions. A thorough breakdown can be read in their Factsheet on Copyright Act 2021. The exceptions listed here are as follows:

reporting news
criticism or review
research or study
educational use by non-profit schools (freely accessible materials found online)
for use in computational data analysis (including use of freely accessible online materials for machine learning)
galleries, libraries, archives, and museums
print-disabled users

Category	Singapore	United States
General Duration*	Life of author + 70 years after death	Life of author + 70 years after death
Berne Convention	Signed on	Signed on
Exemption for Education	Yes, fair dealing	Yes, Fair Use
Registration	Automatic	Automatic

*Some exemptions and specifics exist. Please refer to the corresponding tab for more detailed information.

Is your country not listed?

Let us know if you would like to see your country listed here by emailing us at commons@erau.edu.

This research guide by Heather Crane, Open Education Librarian at Embry-Riddle Aeronautical University, is licensed under a Creative Commons Attribution-NonCommercial 4.0 International License CC BY-NC 4.0.

Open Educational Resources

Copyright in other countries with ERAU Worldwide campuses

European Union

Japan

Singapore

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