Japan has been a signatory to the Berne Convention for the Protection of Literary and Artistic Works since 1899. The convention provides the legal framework under which Japanese manga and anime are protected automatically in other signatory countries — currently 181 nations. Understanding Berne's basic mechanics explains many of the international licensing patterns visible in the modern anime industry.
How the Berne Convention works
Berne grants two core protections: automatic protection (a work is protected in all signatory countries from the moment of creation, with no registration required) and national treatment (foreign works are treated under the same rules as domestic works in each signatory country). For Japanese manga and anime, this means a work is legally protected in France, Brazil, Egypt, or any other Berne signatory from the moment it is fixed in tangible form.
Term of protection
Berne sets a minimum term of life of the author plus 50 years; many signatories (including Japan since 2018, when the term was extended from 50 to 70 years as part of the TPP-11 agreement) provide longer terms. For most modern manga, this means commercial rights remain controlled for the entirety of the author's working career and for at least two generations after.
Practical consequences
Berne creates the legal framework that enables — and constrains — modern anime licensing:
- Crunchyroll, Netflix, and other distributors licence anime country-by-country, since each country's copyright system applies separately.
- Scanlation and fan-subbing of new manga and anime is infringement in every Berne country, regardless of where the scanlation is hosted.
- Region-locking of streaming content reflects the per-country licensing structure rather than technical limitation.
- Translation rights are separately licensed from broadcast rights, which are separately licensed from merchandise rights, all under the same per-country framework.