In June 2025, the European Union (EU Regulation 2019/880) is set to implement a significant regulation and measures to prevent the importation of cultural items that have been illegally exported from their countries of origin, particularly from regions affected by armed conflict.

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Who is Affected?

The regulation affects a broad range of entities involved in the trade of cultural goods, including art dealers, auction houses, museums and any private individual bringing cultural goods into the EU.

‘Cultural goods’ covers a wide breadth of fine arts, antiquities and decorative arts. In order to be included in these measures they need to have been created or discovered in a country outside the Union (that is, a ‘third country’).

There are some exemptions including:

• Goods that originate from the EU
• Goods of an alternative origin which were exported prior to these regulations
• Goods temporarily imported for educational/scientific purposes
• Goods temporarily imported for sale in a commercial art fair.

Where it is not possible to demonstrate with certainty when the goods were discovered, created or left the third country, the importer has the option to prove legal export from the last country where the good was permanently located (for at least five years) before its proposed move to the EU.

What Are the Obligations?

Importers will face different requirements depending on the type and value of the cultural goods, roughly organised as:

• Items illegally removed (as per the country’s domestic legislation) from third countries can not be imported.
• Items from archaeological excavations more than 250 yrs in age will require an import licence (from a designated authority in the Member State where the goods are being imported).
• Items greater than 200 yrs old and valued at over EUR 18,000, will require an importer statement (from the holder of goods in the third country).

The EU will establish a centralized electronic system (ICG) to facilitate the submission of applications for licences and statements, improving efficiency and transparency.

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‍What Are the Risks of Non-Compliance?

Penalties for violating the measures will be confirmed by member states so it is not clearcut, but seizure of objects, fines and criminal convictions where there is evidence of fraudulent activity, are likely to exist across the board.

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You can read the full legislation here.

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The impact of these changes will depend on the specifics of your business. This article is for informational purposes only and does not constitute legal advice.