In respect of a German proposal to allow Member States to maintain existing limitations to the exclusive rights provided they are of minor importance and do not conflict with the single market, we would stress the need for a reassessment of such limitations against the three-step test of Article 5.4 of the draft Directive. Existing limitations may be outdated. How to ensure strong IPR protection as reflected by inter alia statements from TEP, TABD and GBD should be given priority on the agenda. It proposes a right of communication to the public as its central reform. However, the Bill still allows such libraries to charge for reproducing and transmitting copyright works without prior authorisation or payment to rightsholders.
Users can acquire rights to reuse existing material whether on paper or electronically.
RLS allows republication for commercial purposes. Besides increasing revenue opportunities, customer service is enhanced as RLS provides users with a quick way to obtain republishing rights. There is clearly a need for a service that authorises republication of copyrigtht works, both parts of and complete works. Old titles that often run in few editions are requested. CCC's RLS may represent a service that several RROs would wish to follow up on, both in the interest of users and rightsholders.