Draft Regulations Would Severely Restrict the Import of Ancient Coins & Antiquities Into EU

I would not be happy to learn about this if I lived in the EU or sold to people living in the EU. I hope this is not a case of comments being solicited for form's sake, even though the decision to implement the regulations has already been made. The proposed regulations seem clearly to apply to ancient coins as much as other antiquities.

https://culturalpropertynews.org/critical-comments-rain-down-on-draft-eu-regulations/

Kate Fitz Gibbon - April 21, 2021

"The EU Regulation 2019/880, which severely limits the import of ancient art, manuscripts and antiques into the European Union became law in 2019. When EU Regulation 2019/880 is fully implemented through a unified digital import application system in all countries, sometime between 2023 and 2024, it will likely act as a de facto ban on import of antiquities into the twenty-seven current EU nations.[1]

Draft Implementing Regulation and Rules Issued in Late March 2021

The Draft Commission Implementing Regulation (EU) and Annexes to Commission Implementing Regulation (EU) were issued in late March 2021. These are the proposed rules implementing Regulation (EU) 2019/880 of the European Parliament and of the Council on the introduction and the import of cultural goods into the European Union. In 45 pages of rules and recitals, the draft provisions outlined the rules and documentation that will be required for importing art and antiquities into Europe.

Despite the lack of any evidence that the EU legislation is necessary to combat looting in unstable or war-torn countries, supporters in Parliament, among archaeological organizations and anti-trade activists have continued to argue that the art trade supports terrorism. This canard is reiterated in the proposed implementing regulations.

The EU requested comments on the implementing regulations via its “have your say” website. Despite the rules’ complexity, only a 4-week period for public comment was allowed. The majority of the 50+ submitted comments were critical of the proposed rules, many finding that they threatened the future circulation of art throughout the EU and would prove devastating to the art market and thence to collectors and museums. . . . .

Regulation 2019/880 Impacts the following goods.

For the reader who is not familiar with the underlying legislation Regulation 2019/880 to which the draft implementing rules apply – it will restrict import and export of items over 250 years of age into the EU. For ancient art and “archaeological” materials, Regulation 2019/880 requires either documentation of lawful export from the source country (although the majority of countries have no such permitting regimes) or in exceptional cases, if the source country cannot be determined, the exporter must provide documentation from a second country in which the object has been for at least five years. For other categories of art, it requires a sworn affidavit from the exporter that the item meets the same criteria. A key concern regarding the affidavit system is that the importer may have no way to know if that is true or not, since cultural items may have circulated for decades among multiple owners.

‘Article 4’ Items Requiring Proof of Legal Export from Source Countries to Obtain Import Licenses are:

(1) products of archaeological excavations (including regular and clandestine) or of archaeological discoveries on land or underwater, (2) elements of artistic or historical monuments or archaeological sites which have been dismembered, and (3) liturgical icons and statues. Effectively, the Article 4 requirements for import licenses could apply to all antiquities including most ancient coins.

‘Article 5’ Items Requiring a Sworn Affidavit for Entry include:

rare collections and specimens of fauna, flora, minerals and anatomy, and objects of palaeontological interest
property relating to history, including the history of science and technology and military and social history, to the life of national leaders, thinkers, scientists and artists and to events of national importance;
antiquities, such as inscriptions, coins and engraved seals;
objects of ethnological interest;
objects of artistic interest, such as:
pictures, paintings and drawings produced entirely by hand on any support and in any material (excluding industrial designs and manufactured articles decorated by hand);
original engravings, prints and lithographs;
original works of statuary art and sculpture in any material;
original artistic assemblages and montages in any material;
rare manuscripts and incunabula;
old books, documents and publications of special interest (historical, artistic, scientific, literary, etc.) singly or in collections

The businesses likely to be hit hardest by the regulations are the legitimate traders, auction houses and small galleries dealing in art and collectibles in major art centers. These businesses are already subject to regulations on import and export transactions, banking, and tax collection under national laws. The U.S., E.U. and U.K. together dominate the approximately $800 billion annual arts industry and trade among these nations is very active, with the majority of the objects having been in circulation for decades.

The Committee for Cultural Policy also submitted commentary on the draft implementing Regulation (EU) 2019/880. We find serious fault with the proposed regulations, which we believe will threaten the most active art exchanges in the world – those between the United States and the EU and the UK and the EU, while doing little to stem illicit trafficking and having no effect whatsoever on terrorist financing through art. " {Rest of article at link.)

I also highly recommend this just-published three-part article at the same site entitled "The Antiquities Trade: A reflection on the past 25 years" -- although it actually discusses the history of the trade back to the 19th and early 20th centuries, when the Cairo Museum had a sale room where buyers could purchase genuine antiquities! It doesn't really address ancient coins specifically, but most of what's said (especially about efforts to restrict the trade) would apply just as much to the ancient numismatics market. See:

https://culturalpropertynews.org/the-antiquities-trade-a-reflection-on-the-past-25-years-part-1/

https://culturalpropertynews.org/the-antiquities-trade-a-reflection-on-the-past-25-years-part-2/

https://culturalpropertynews.org/the-antiquities-trade-a-reflection-on-the-past-25-years-part-3/

 

Log in or Sign up to hide this ad.

What a nest of hypocrites...after looting Ancient Greece, i.e coins inter alia Elgin Marbles, etc. early on, they grow a conscious?
Yeah, Right,
J.T.

Addendum: We got ours...Sucks to be you!

 

Thanks for sharing. Seems that many EU countries enjoy making regulations.
I assume all those regulations may well impact not only EU countries, but also non-EU.

 

So rather than actually, oh I don’t know, track down the terrorists or institute far more stringent methods of verifying purchasers of said items, the bureaucracy decides to just ban something outright. Reminds me of zero tolerance policies here in the US. Critical thinking is going down the drain…

 

All of this, including the American memoranda of understanding, is continuing implementation of the 1970 UNESCO Convention. We are well beyond the point of no return, imho.