Comments submitted jointly by EIFL and representatives of the international library, archives and museum communities to WIPO (the World Intellectual Property Organization) on the Toolkit on Preservation (document SCCR/43/4) calling on WIPO to finalize the Toolkit without making any further changes to the text.

Signatories to the comments agree that the Toolkit represents a major step forward for promoting modern copyright exceptions for the preservation of cultural heritage, and provides countries with essential guidance on how to craft an exception that enables preservation using 21st century digital technology. In particular, it affirms that anticipatory preservation is critical to meet the many threats to the collections of cultural heritage institutions, including fires, floods and the illicit trafficking of cultural property. 

An important concern, however, is that the Toolkit does not deal with the issue of access, that is, making preservation copies available. 

The comments were submitted by EIFL, the Library Copyright Alliance (LCA); the International Federation of Library Associations & Institutions (IFLA); the Society of American Archivists (SAA); the International Council on Archives (ICA) and the International Council of Museums (ICOM).