1. The context
Since the adoption of EU Regulation 2019/880, cultural goods entering the Union must be accompanied by proof of lawful export from their country of origin. Without this documentation, customs can suspend or even block entry.
These measures do not concern works created or discovered within EU territory, but they do affect any object arriving from abroad, whether for a temporary exhibition, a sale, or a private collection.
Art and heritage have an inestimable value. Not only on paper, but also for the history and identity of a country. Yet, too often, precious cultural goods disappear from their country of origin, sometimes even to finance terrorism. This is why Europe is determined to fight against the illegal trade in artworks and antiquities, in order to protect the heritage of other countries and safeguard the integrity of the art market.
Etienne Mignolet, spokesperson, FPS Economy
2. Which arts works are concerned?
The regulation does not target a single type of object but rather a wide range of cultural goods:
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List A – Illicitly exported archaeological objects. Their import is strictly prohibited.
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List B – Cultural goods (e.g. manuscripts, coins, antiquities over 250 years old). Require an import licence.
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List C – Other cultural goods over 200 years old and valued above €18,000. Require an importer statement.
Exceptions exist for temporary admissions (exhibitions, conservation, etc.).
3. Ensuring compliance before crossing the border
At the border, customs officers will verify documentation. Missing papers can cause weeks of hold.
To avoid these complications, clients must be aware of the specific invoicing and documentation requirements introduced by the regulation.
Some cultural goods (List B above), especially those over 250 years old, now require an import licence.This document can be obtained prior to shipping and will be checked by customs before the works are cleared for entry.
For other categories, such as items older than 200 years with a customs value above €18,000, an importer statement will be necessary (Items from List C above). This statement confirms the legality of the object and its provenance.
A third cornerstone of compliance is the proof of lawful export. Collectors, galleries, or institutions must be able to demonstrate that the goods were legally exported from their country of origin. This often involves presenting export certificates, provenance records, or other supporting evidence secured in advance.
Good to know :
If a shipment reaches the EU without the right paperwork, we can place the goods under customs control in our bonded warehouse while the situation is regularised (e.g. obtaining an import licence or filing the importer statement). Storage and handling charges apply, but it prevents border blockage and buys the time needed to comply.
The customs authorities do not automatically provide advice on every item. It is highly recommended to contact them in advance with age, value and origin, in order to confirm the required documents.
4. Preparing your shipping
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Be proactive and early: Contact customs as soon as you plan to import cultural goods covered by the regulation. Early communication helps identify the required documents and prevents surprises at the border.
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Check for licences or statements: Depending on the type of object, you may need an import licence (for older works, especially over 250 years) or an importer statement (for works over 200 years with a certain value). Make sure these are ready before shipping.
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Gather proof of lawful export: Customs will ask for evidence that the goods left their country of origin legally. Export certificates, provenance records, or similar documentation should be secured in advance.
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Prepare for potential delays: Even with preparation, customs inspections can take time. Anticipating possible delays ensures that your logistics remain under control.
By engaging early with customs, securing the right paperwork, and planning for inspections, clients can avoid blockages and guarantee that their cultural goods enter the EU without unnecessary risk or delay.
How Embelco supports you
At Embelco, we understand how critical these procedures are. For more than seventy-five years, we have been managing the transport of artworks and cultural goods with precision and care.
Our promise is simple: to give you peace of mind. By anticipating regulatory requirements and handling every detail from nail to nail, we ensure your artworks travel safely and arrive on time — fully compliant with European law.
Sources
https://news.economie.fgov.be/251515-de-nouvelles-regles-pour-l-import-de-biens-culturels/
https://economie.fgov.be/fr/themes/politique-commerciale/licences/importations-de-biens
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX%3A32019R0880&rid=1
