The US legislation allows a number of bars, restaurants and retail outlets to be exempt from paying royalties for playing music on their premises.
Speaking at a Westminster Media Forum on the global music market earlier this week, John Mottram, head of policy and public affairs at PRS for Music said: 'Research shows that the bars and grills exception costs musical rightsholders $150m (£112m) every year, of which $44m (£33m) is due to EU rightholders.'
Mottram said these findings by the European Grouping of Societies of Authors and Composers (GESAC) explain, in part, why the value of music broadcast in the US is worth 'just over half of what it is in the UK'.
'In the UK, total collections against performing rights on a per capita basis equals about £5.20 per person, whereas in the US – the world’s largest music market – it represents less than £3 per person,' he said.
Describing the shortfall as 'an obvious example of where money is falling out of the system because of copyright exceptions’, he went on to give the example of China, which despite its 1.6 billion population, has a performing right value of 'less than a penny,' based on the same per capita basis.
'There is simply not a copyright regime that properly protects our rights in those markets. As the UK enters trade negotiations post-Brexit, it is essential the UK government secures in these deals protections for authors’ rights,' he added.
Mottram made the comments at the Westminster Media Forum in London, as part of a panel titled, The digital landscape: opportunities, industry relationships and the impact of new technology.
Other speakers on the panel included John Enser (CMS), Kieron Faller (CI) and David Glick (Edge Investments).