Draft amendments to the regulation on reprographic fees – AmCham’s position and letter from a coalition of digital sector organizations

AmCham is involved in the debate on changes to the reprographic fee system. As signatories to a letter from a coalition of digital sector organizations and in our own position paper, we expressed our critical stance on the Ministry of Culture’s proposal. Among other things, we pointed out that the changes proposed by the ministry:

1) Are based on inadequate assumptions about the functioning of the modern digital economy, in which streaming and other forms of legal use of works that do not require copying are playing an increasingly important role,

2) May violate European Union law due to the lack of a basis in actual financial damage to creators,

3) Exceed the statutory delegation.

4) Insufficiently protect the interests of commercial users, who should be excluded ex ante from the reprographic fee system.

The letter from the coalition of organizations can be found here, and AmCham’s full position can be read here.