Alternative Compensation Systems

In: Elgar Encyclopedia of Intellectual Property Law, , Edward Elgar Publishing, 2025, ISBN: 9781800886926

alternative compensation systems, collective rights management, Copyright

RIS

Save .RIS

Bibtex

Save .bib

State-of-the-Art Geo-Blocking is Good Enough, Even if VPNs Enable Circumvention: The CJEU on Territorial Copyright and the Public Domain in Anne Frank Fonds external link

Kluwer Copyright Blog, 2026

Abstract

Territorial copyright and the borderless Internet have never sat comfortably together. The CJEU’s judgment in Anne Frank Fonds (C-788/24), delivered on 9 July, demonstrates that this tension remains very much alive. Faced with works that have entered the public domain in some Member States but remain protected in others, the Court concludes that geo-blocking retains legal significance for copyright law purposes despite the possibility of VPN circumvention, provided that it qualifies as an “effective technological measure” within the meaning of Article 6(3) of the InfoSoc Directive – that is, a technological measure intended to prevent or limit acts not authorised by the copyright holder (paras. 44-56).

Copyright, Geoblocking, public domain

RIS

Save .RIS

Bibtex

Save .bib

The Validity of the Residual Right of Remuneration under Articles 17 and 18 CDSMD: Opinion of the European Copyright Society in Streamz (Case C-663/24) external link

Benabou, V., Dusollier, S., Geiger, C. & Senftleben, M.
IIC, 2026

Abstract

In its questions for preliminary ruling to the CJEU, the Belgian Constitutional Court asks for clarification as to whether the remuneration rights enacted by the Belgian lawmaker when implementing the Directive 2019/790 on Copyright in the Digital Single Market (CDSMD), in the field of streaming service providers and of open content sharing service providers, are compliant with EU law. In the present Opinion, the European Copyright Society takes the view that an inalienable and non-transferrable remuneration right is a lawful mechanism under EU copyright law to ensure that authors and performers receive fair remuneration for the exploitation of their works and performances. The fair remuneration rationale rests on fundamental rights protection and constitutes an objective and key principle of EU copyright law, as affirmed by recent CJEU case law. Article 18 CDSMD requires Member States to ensure that authors and performers are entitled to an appropriate and proportionate remuneration when they license or transfer their exclusive rights, but states that Member States are free to choose the mechanisms to achieve that purpose. This flexibility allows national copyright laws to complement obligations of remuneration in the contractual sphere with residual rights of remuneration (RRRs), that authors and performers, generally through a collective management organization, can directly assert against economic operators exploiting their works and performances. Article 18 provides only minimum harmonization and is formulated in a way that does not require remuneration to be achieved solely through contractual arrangements between creators and their immediate contractual partners. RRRs are well established within the EU and Member States copyright law. The Rental and Lending Rights Directive already provides authors and performers with an unwaivable right to equitable remuneration for rentals. Similar remuneration mechanisms exist in several Member States for diverse modes of exploitation. The mechanism of RRR does not unduly interfere with exclusive rights. Authors and performers benefit from full exclusive rights but retain a right to remuneration (hence called residual) after they transfer or license them. This legal technique dissociates the exclusive right, necessary to authorize the reproduction, communication or making available to the public, from the right to be remunerated for such exploitation. The ECS also rejects the claim that RRRs create double payment obligations. Legally speaking, the remuneration paid under exploitation contracts concluded with producers or publishers and the remuneration paid under an RRR arise from different legal bases. Rather than requiring platforms to pay twice for the same use, the mechanism reallocates part of the overall revenue stream to creators. It is therefore a redistribution mechanism rather than an additional layer of compensation. It is in line with EU copyright law and CJEU case law admitting that the many entitlements and rights under copyright and related rights can be unbundled and separately assigned for distinct modes of exploitation. The RRR is not an exception or limitation to copyright either: it does not replace or substitute an exclusive right (as is the case with the right performers and phonogram producers to claim remuneration for broadcasting of phonograms) and it is not a compensatory system for a legally authorized use (as in the case of private copying). Regarding freedom of contract and freedom to conduct a business, the Opinion acknowledges that RRRs may require the economic operators concerned to deal with collective management organizations despite the conclusion of an exploitation contract. However, such limitations pursue legitimate public-interest objectives, namely correcting structural bargaining imbalances and ensuring fair remuneration for creators, in a proportionate manner. The RRR, provided for in Belgium in the field of online content-sharing, is not contrary to Art. 17 CDSMD, which governs online content-sharing service providers. The maximum harmonization pursued by Art. 17 only pertains to the obligation for online content sharing service providers to obtain an authorization for the making available of works and other subject-matter, and to the specific liability regime it lays down. It does not regulate how artists should be remunerated once authorization has been obtained. Remuneration issues remain governed by Arts. 18–23 CDSMD, which expressly allow Member States flexibility in implementing fair-remuneration mechanisms. National RRR systems therefore complement, rather than conflict with, Art. 17. In conclusion, Member States may lawfully introduce RRRs as a means of ensuring that authors and performers receive a fair share of the economic value generated by the exploitation of their works and performances.

CDSM Directive, Copyright, remuneration

RIS

Save .RIS

Bibtex

Save .bib

The concept of lawful access and its implications for user freedoms in the EU copyright acquis: Opinion of the European Copyright Society external link

Margoni, T., Kretschmer, M., Metzger, A., Quintais, J. & Synodinou, T.
Kluwer Copyright Blog, 2026

Abstract

The advent of digital technologies and connected patterns of production and consumption has progressively displaced ownership in favour of access as the predominant mode of enjoyment of works of authorship and other information goods. This transition from acquiring physical copies to subscribing to digital services has become prevalent across various sectors and has even enabled new commercial, cultural and scientific practices. However, it also marks a major shift in the theory and function of copyright: it transforms a right primarily concerned with regulating certain exploitations and circulations of works into one capable of controlling individual acts of access and use.

Copyright

RIS

Save .RIS

Bibtex

Save .bib

Greening EU Intellectual Property Law through the Human Right to a Healthy Environment: An Operative Methodology for Constitutional Interpretation external link

Abstract

Can the human right to a clean, healthy and sustainable environment (HR2HE) reshape the interpretation of EU intellectual property (IP) law? This chapter argues that the question is no longer whether environmental protection should influence IP law, but how it should do so. Drawing on international environmental law, United Nations practice, regional human rights jurisprudence and EU constitutional law, it reconstructs an operative methodology for translating the constitutional relevance of environmental protection into concrete legal reasoning. The resulting three-stage framework distinguishes three questions: why environmental protection is constitutionally relevant to the interpretation of IP law; whether and to what extent the activity at issue genuinely advances constitutionally protected environmental objectives; and how those objectives should be reconciled with the legitimate purposes of the IP regime concerned through the interpretation of its existing doctrines. The chapter illustrates the methodology through the recent Hermès upcycling litigation before the Paris Judicial Court. It argues that the HR2HE need not operate primarily through new environmental exceptions or defences, but can function as an internal constitutional consideration informing the interpretation of open-textured IP doctrines wherever they leave room for judicial choice.

Copyright, healthy environment, Human rights, Intellectual property

RIS

Save .RIS

Bibtex

Save .bib

Copyrighting Style? Reframing Style Imitation as Non-Literal Copying in EU Copyright Law: Implications for Generative AI and Fashion Dupes external link

Abstract

The proposition that artistic style falls outside copyright protection is widely regarded as axiomatic in copyright law. Under the idea/expression dichotomy, authors may claim exclusive rights over the specific expression of their ideas, but not over artistic styles, genres or aesthetic vocabulary. Recent developments, however, have made the copyright treatment of style increasingly difficult to ignore. Generative artificial intelligence can produce works in the recognisable style of individual creators within seconds, while fashion dupes systematically reproduce the aesthetic language of successful luxury designs without literal copying. These developments have prompted renewed interest in the relationship between copyright and artistic style. This article argues that the central question has been framed too broadly. The issue is not whether copyright should protect style itself. Rather, it is whether conduct described as “style imitation” may already constitute the non-literal reproduction of protected expression under existing EU copyright law. Revisiting the Court of Justice’s jurisprudence on originality and the reproduction right, the article demonstrates that the existing framework already provides the doctrinal tools necessary to distinguish between lawful stylistic inspiration and copyright infringement. It concludes that AI-generated outputs and fashion dupes do not expose a need to copyright style, but rather a need to recognise more clearly when apparent stylistic borrowing is, in reality, the non-literal reproduction of protected expression.

Copyright, Fashion, Generative AI

RIS

Save .RIS

Bibtex

Save .bib

The EU Can No Longer Let Fashion Go Up in Flames: The Ban on Destroying Unsold Clothes Marks a New Stage in EU Market Regulation external link

Verfassungsblog, 2026

Copyright, EU, Fashion, Regulation

RIS

Save .RIS

Bibtex

Save .bib

Is Upcycling Always Green – and Should It Be? Reconsidering the Rationale for Accommodating Upcycling within IP Law and Leveraging the Potential of Quotation and ‘Due Cause’ external link

GRUR International, vol. 75, iss. : 8, pp: 719–729, 2026

Abstract

Climate change has forced legal systems to question many of their long-standing assumptions, including the largely linear logic that continues to underpin intellectual property (IP) law. Existing scholarship has convincingly shown that copyright and trade mark laws often hinder circular practices such as repair and upcycling, prompting calls for greater flexibility or the ‘greenification’ of IP law. This article challenges a key premise of those proposals: that upcycling is inherently environmentally beneficial. The environmental value of upcycling is neither uniform nor self-evident, and in some contexts may be marginal or even adverse. This uncertainty raises a normative question: should accommodation of upcycling under IP law depend on demonstrated environmental benefit, or does upcycling embody a wider social value warranting protection irrespective of ecological impact? The article argues for the latter, developing a justificatory framework grounded not primarily in environmental sustainability, but in artistic freedom and cultural diversity. On this account, environmental benefits – where present – serve as reinforcing considerations rather than the foundation for legal reform. Building on this reframing, the article reassesses concerns about free-riding on IP holders’ rights and argues for a more calibrated balance between upcycling practices and the protection of legitimate IP interests. It then examines how this balance might be realised within existing EU IP law, focusing on the underexplored potential of the quotation exception in copyright law and the ‘due cause’ defence in trade mark law. By repositioning these defences within the sustainability discourse, the article seeks to broaden the tools available to courts and policymakers for aligning IP law with the social value of upcycling.

Copyright, Freedom of expression, Trademark law, upcycling

RIS

Save .RIS

Bibtex

Save .bib

The concept of lawful access and its implications for user freedoms in the EU copyright acquis: Opinion of the European Copyright Society external link

Margoni, T., Kretschmer, M., Metzger, A., Quintais, J. & Synodinou, T.
2026

Copyright

RIS

Save .RIS

Bibtex

Save .bib

Misleading Claims about the Secondary Publication Right external link

Kluwer Copyright Blog, 2026

Copyright

RIS

Save .RIS

Bibtex

Save .bib