Just a reminder that we are the only country with the first amendment and a constitutionally guaranteed right to free speech.
Even China's constitution says "Citizens of the People's Republic of China enjoy freedom of speech, of the press, of assembly, of association, of procession and of demonstration."
Of course, that doesn't apply in practice, but that is my point. Just having an article in the constitution granting you a right does not guarantee that right in practice.
You are referring to article 10 which comes with a very big caveat:
The exercise of these freedoms, since it carries with it duties and responsibilities, may be subject to such formalities, conditions, restrictions or penalties as are prescribed by law and are necessary in a democratic society, in the interests of national security, territorial integrity or public safety, for the prevention of disorder or crime, for the protection of health or morals, for the protection of the reputation or rights of others, for preventing the disclosure of information received in confidence, or for maintaining the authority and impartiality of the judiciary.
Compare it to the 1st Amendment:
Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press; or the right of the people peaceably to assemble, and to petition the Government for a redress of grievances.
So yes, the US is pretty much unique in the way it refers to freedom of speech both de jure and de facto. Article 10 pretty much says, yeah we respect the fact that in theory you should be able to say what you want, but make sure it doesn't offend anyone.
Obviously, the ECHR, being between countries which lack the commonality of legal history and political culture had to make express what would be understood from context in a framework where the participants shared more deeply in a common legal history and political culture, but the substantive meaning isn't all that different.
You won't see things like this in the US http://europa.eu/rapid/press-release_IP-16-1937_en.htm
Some European countries (such as Sweden and Germany) and the EU as a whole have been stepping up censorship of both social and traditional media these past few years. While it's easy to classify this as just fighting "right wing extremist" much of what is being censored wouldn't be considered right wing nor extremist in the academic sense in any way.
This does not only include traditional "hate speech" like immigrants are bad... mmkay or jews are evil but goes deeper and threatens to classify any criticism of EU policies or anything that causes political disturbance as "hate speech". Whats even more disturbing is that many of these measures are enacted on the back of terrorist attacks in Europe and over the world, but end up being used in combating local political dissent.
If you'll want to make an analogy to what happens in the US then the latest EU movements to cramp freedom of speech are not that different than the massive surveillance program that the US embarked on post 9/11, if anything it is probably worse. While surveillance might have a negative effect on expression and it sure can help breed homogenous group think, dictating what can and cannot be said, and what should are should not be thought is considerably more dangerous.
There are plenty of things in USA you can say on social media which will at best add you to a watch list, at worst place you in jail.
>Freedom of expression is granted by Article 5 of the Basic Law for the Federal Republic of Germany, which also states that there is no censorship and freedom of expression that may be limited by law.
The US is in fact the only developed country that has no laws banning hate speech, including no legal recourse for outright lies like Holocaust denial.
Not in a way that would make sense as "free speech" to an American.
It's probably more accurately parsed as freedom of the press.