I should clarify that noncommercial use something different: an exemption for commercial activity. What copyright enforcement can't recover is income from activity that couldn't have generated revenue, in the first place. If I draw a Nintendo character on my own T-shirt, and never sell that T-shirt, that's not a copyright violation, because there's no way I could have made money from it. Whereas, if I draw a character on a T-shirt, then give it away for free, it's noncommercial activity, but it could be subject to copyright, because I could have charged for it.