Publishers’ association of south africa

The Anglo-American model uses a system of voluntary contracts with rights holders (both individual rights holders and organisations representing rights holders), and negotiated licence agreements with users. Distribution of income collected is based on statistical data, and undertaken on a title-specific basis. This provides maximum freedom of choice for participants, but does require a lot of administration and the exclusion of certain rights holders can be a disadvantage to users.

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  The German-Spanish model rests on statutory provisions in those countries, which permit a levy attached to the sale of photocopying machines. The levy is determined by regulation, and varies according to the type and capacity of the machine, and according to its location and use.
  

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  The Dutch model is based on a statutory licensing system for reproduction rights. In government and in education users may copy but must pay, the law determining the fees. In higher education (for course readers and study packs), fees are negotiable.
  

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