The Regolamento europeo antichità that came into force on June 28, 2025, radically redefines the importation of ancient works and cultural goods into the European Union.
After the reduction of VAT on artworks in Italy, another major development for the art trade.
This measure, while on one hand aims to curb the illicit traffic of art, on the other raises issues in the commercial chain, in research, and in exhibitions, generating uncertainty about procedures and operational limits.
The new EU rules against the illicit trafficking of antiquities
The Regulation (EU) 2019/880, whose application officially began on June 28, 2025, imposes a enhanced due diligence for every cultural good imported into Europe and Italy. Importers must now produce comprehensive and detailed documentation on the legitimate provenance of the works, justifying both the export from the country of origin and the import into the EU.
The regulation was created after documented cases of looting in archaeological sites in Syria and Iraq, which highlighted the risks associated with the illegal trafficking of antiquities. The measure extends to a wide range of objects: works of art, antiquities, archaeological finds, decorative art, and collectible goods, aiming to counteract the criminal flows that finance even terrorist organizations.
At the base, the reasoning of the EU is that il patrimonio culturale represents an essential value for all societies, whose loss constitutes a global wound. However, the complexity of the new regulations raises questions and above all slows down the legitimate circulation of works.
What changes in the trade of antiquities between new categories and obligations
The provisions of the EU regulation outline specific rules, dividing the beni culturali that can be imported into three macro-categories:
- Illegal exports: completely prohibited. No goods exported illegally can enter the EU, without exceptions.
- Archaeological finds and goods over 250 years: for these, regardless of the value, an import license is required to be obtained before entering the EU. The importer must provide documentary evidence that excludes illegal export from the country of origin.
- Goods over 200 years old and value exceeding 18,000 euros: require a signed declaration from the importer certifying the legality of the export, accompanied by a description of the items.
In the absence of the required prescriptions, the seizure of assets and possible criminal consequences are foreseen. Traceability and compliance with procedures become an essential condition for every international operation.
The digitalization of practices: mandatory platforms and procedures
The application of the Regulation 2019/880 involves the use of advanced digital tools to manage the practices. The heart of the system is the international database ICG (Import Cultural Goods), integrated into the digital platform TRACES NT, which centralizes all European requests related to the importation of cultural goods. Operators must register and submit documentation exclusively through these digital channels.
- For goods over 250 years old, the license application must be submitted through ICG, including any proof of legality of export. If the country of origin cannot be identified, or the good was removed before April 24, 1972 (date of the UNESCO Convention on the protection of world heritage), it is necessary to demonstrate the legitimate export from the last country where the object was kept for at least five years.
- Are accepted as evidence: cataloghi d’asta, fatture, polizze assicurative, documenti di trasporto and property titles.
- For temporary imports (exhibitions or fairs), a declaration can replace the license, provided that the good is then re-exported; if sold and retained in the EU, the license becomes mandatory.
- For goods over 200 years and value above €18,000, a declaration is sufficient, also in this case through ICG, except for the impossibility of identifying the country of origin. Here too, reference is made to the last place of detention for at least five years, with procedures similar to the other categories.
The competent authorities must respond within 90 days from the application; any requests for additional documentation reset the time count.
The main issues of the European antiquities regulation
Despite the legitimate desire to curb illicit art trafficking, operators and industry professionals complain about several issues. The first concerns the overly broad definition of object categories, which groups together archaeological finds, ancient paintings, jewelry, and various collectibles under the same rules.
The value thresholds set (18,000 euros for significant imports) are so low that they involve the majority of market negotiations, while the required bureaucracy becomes increasingly burdensome. One of the concrete difficulties lies in the request for documentary evidence: often, despite the legitimacy of the operation, archives or historical certificates are missing because in the past documentation was not kept longer than necessary.
Another obstacle concerns administrative management. The Export Offices and the Superintendencies are often understaffed, and the number of cases is bound to increase, making it more difficult to obtain quick responses and efficient procedures.
The exceptions for educational and cultural purposes: what limits?
The European antiquities regulation includes exceptions reserved for educational, scientific, conservation, and research purposes, such as temporary exhibitions, digitization, and academia. These exemptions apply only to loans between museums or similar institutions outside the EU. Private lenders are excluded: the risk of sanctions, if the documentation proves insufficient, will hinder the willingness to participate in cultural events, impoverishing both research and temporary exhibitions.
The result is the widespread feeling among operators of a preventive criminalization of the sector, with the difficulty of distinguishing between those who operate in good faith and the real traffickers. In this new climate, the circulation and enhancement of works of art risk experiencing a drastic slowdown.
What future for the art trade in Europe?
The entry into force of the regolamento europeo antichità represents an important turning point in the control of international flows of works of art, increasing transparency and traceability. However, procedural complexity and interpretative uncertainties risk drastically reducing the participation of operators, collectors, and international researchers.
It will be essential to monitor the real impact of these rules and ensure that the protection of the patrimonio culturale does not stifle the vitality of legal art trade and scientific research. Greater regulatory clarity and the strengthening of administrative structures could offer a balance point between security and cultural enhancement, allowing the European system to be truly competitive and sustainable.
As expert in digital marketing, Amelia began working in the fintech sector in 2014 after writing her thesis on Bitcoin technology. Previously author for several international crypto-related magazines and CMO at Eidoo. She is now the co-founder and editor-in-chief of The Cryptonomist and Econique.
She is also a marketing teacher at Digital Coach in Milan and she published a book about NFTs for the Italian publishing house Mondadori, while she is also helping artists and company to entering in the sector. As advisor, Amelia is also involved in metaverse-related project such as The Nemesis and OVER.
