Some considerations on moral rights in the USA and in the EU today

Abstract

Abstract: Alcune considerazioni sui diritti morali negli Stati Uniti e nell’Unione europea oggi – The USA joined the 1886 Berne Convention for the Protection of Literary and Artistic Works only in 1989, with the Berne Convention Implementation Act (BCIA). Thirty years later, the Copyright Office published in April 2019 an extensive study about the American protection of moral rights. The document is studied in comparison with the European Directives and in particular with the Copyright Directive definitively approved a few days before the Copyright Office document. While in the USA the limited interest in moral rights seems to be increasing, in Europe the protection of moral rights risks being waned as it is handed down to individual countries with the explicit declaration that it is not the subject matter of the Directives.