As of the end of June, new EU regulations will change how cultural goods, fine art, and antiquities enter the European Union from outside its borders. These changes matter—both for customs agents and art dealers. However, they also apply to anyone moving art internationally: collectors, auction houses, art advisers, insurers, and even the superyacht world.
The new legislation, Regulation (EU) 2019/880, along with two similar Acts, aims to protect cultural heritage and combat the illicit trafficking of art and artifacts. However, it also introduces a significantly more demanding regime for import compliance, which now includes new criteria. For example, works of art created before 1825 with a value exceeding €18,000 are now subject to these requirements.
The driving force behind the new law is clear: to close the door on trafficking and restrict the use of art to finance criminal networks, including terrorism. At the same time, it tightens how cultural goods are classified, imported, and tracked through a new digital system that is an import of Cultural Goods interface.
Will these laws create a shift in How Art Moves?
Under the revised framework, importers will now be required to submit either an ‘importer statement’ or, in some cases, apply for a formal import license through the system interface. This encompasses various categories under Chapter 97 of the EU TARIC code related to cultural property, archaeological finds, and fine art.
Crucially, goods that are temporarily brought into the EU for art fairs can enter under a temporary admission procedure with just a statement. However, if those goods are sold and remain in the EU after the sale, a formal import license must be obtained.
Collectors and galleries transporting works from the UK should take note, as the regulation applies to all non-EU countries, including post-Brexit Britain. However, Northern Ireland remains part of the EU customs union, so goods originating there will not be affected.
There are, however, some exemptions. For example, for so-called “returned goods.” These items are ones that had previously left the EU but are now coming back within three years. Provided they meet the requirements of the EU’s customs code, these may not require certain declarations on re-entry.
What This Means for the Art Market – Is it more red tape?
This is more than just red tape; it concerns stopping conflict antiquities and preserving our culture for future generations. The new regulation introduces a significant shift in the legal and logistical responsibilities for moving cultural objects across borders. Importers will need to maintain clear documentation of origin, ensure provenance can be proven, and preempt any delays caused by paperwork shortfalls. This entails research and getting your house in order.
The expanded definition of what counts as a “cultural good” and the increased powers given to customs authorities mean seizures, fines, and even criminal penalties are now very real risks for those who aren’t up to speed.
Is there any training or help in navigating the customs procedures?
To support the art and luxury sectors through this transition, Alinea Customs and Art on Superyachts have collaborated to deliver a targeted training programme. The masterclass, launching ahead of the June deadline, will offer step-by-step guidance for professionals working with art in transit — from gallerists and logistics specialists to collectors and legal advisers.
The course will provide practical tools and reference materials, clarifying which documents are required, how to use the ICG system, and how to mitigate the risk of non-compliance.
Furthermore, Pandora Art Services (Art On Superyachts) offers assistance with conducting inventories and supporting documentation, while Alinear Customs manages the customs clearance process and guides clients through import and export clearance procedures.
About the authors: Pandora Mather-Lees, founder of Art on Superyachts, is an art historian and art due diligence specialist known for her work across museums, auction houses, and the high-value marine art world. She trains superyacht crews in the care and protection of onboard art and advises collectors on insurance and risk. Pandora Mather-Lees | Art on Superyachts, [email protected]
Holly Piggott, Director at Alinea Customs, holds an LLM in International Corporate and Commercial Law and has extensive experience in the customs handling of fine art, cultural objects, and luxury items, particularly for clients in the gallery, auction, and design sectors. Holly Piggott | Alinea Customs, [email protected]