Stefan Zotti, Team Leader “Cultural Heritage,” Directorate-General for Education, Youth, Sport and Culture, led the meeting.  Attendees included representatives of other CINOA^[1] affiliated trade groups, academics, European Commission officials, and a UNESCO representative.

At the beginning of the meeting, Dr. Anne-Sophie Radermaker, University Libre de Bruxelles, presented a positive report about the benefits of the art trade to protecting low value items that would otherwise be ignored in museums and in fostering cultural exchange.  

The rest of the meeting provided an opportunity for the art trade to express concerns about European Commission rules on the import of cultural goods originating outside the EU, consideration of mandates for dealers to create object and client registries, and proposals for additional anti-money laundering regulations.  

The new import rules impacting objects originating outside the EU will be in full effect in June 2025 with the roll out of a web-based system for importers.  Under these new rules, coins in trade (along with most else) over 200 years old and over €18,000 Euros in value will need to be imported with statement proving that they were legally exported from their country of origin.  If this cannot be proved, it will instead be required to demonstrate their provenance outside their country of origin back to 1972.

Unfortunately, during the meeting, a responsible official confirmed that another derogation, applying to situations where the place an item was created or discovered is unknown, does not apply where either fact is known. Thus, since we know the place where most coins were minted, this derogation, will not apply.  

The IAPN will continue to monitor these new rules and will issue a more formal guidance as we get closer to their effective date.

^[1] Confédération Internationale des Négociants en Œuvres d’Art [CINOA]