ILAB response to proposal for a regulation of the European Parliament and of the Council on the import of cultural goods

Over the past few months, the International League of Antiquarian Booksellers and its members, the national antiquarian booksellers associations have campaigned against a EU proposal which aims to combat the illegal import of cultural goods, including books over 250 years old into the EU. Importers will have to obtain import licenses from the EU and go through a rigorous certification system by submitting a signed statement or affidavit as proof that goods have been exported legally.

ILAB agrees with peer trade bodies of the international arts market that any activity financing terrorism or allowing money laundering has to be eliminated. But the current proposal, soon to be debated in the European Parliament, is likely to have a detrimental impact on the antiquarian booksellers who ILAB represents and considers subjecting dealers to administrative obligations that are disproportionate with the pursued objective.

Message from ILAB Vice-President, Fabrizio Govi
London in June, 2018:

ILAB believes that value thresholds would be instrumental to make the Regulation effective, practicable and not a heavy burden on legitimate trade. Even though ILAB disagrees with the very principle of a regulation, it strongly supports value thresholds for printed books (including incunabula, which are simply books printed in the 15th century) and manuscripts, the vast category of which includes not only valuable Medieval codices, but also anything that was handwritten until today and presenting no value. As proposed in the amendments sent by ILAB to both Commissions in the month of April, the ideal threshold for printed books and manuscripts would be €150,000 or at least the € 50,000 set as a limit in the EU export regulation.

ILAB also believes that the entire concept of source country should not apply to printed books and manuscripts, apart from those non-Western manuscripts coming from war zones and troubled countries. In many cases, it is very complicated or even impossible to establish a clear origin for many manuscripts, since they often bear no date or place and are not signed.

One of the other declared purposes of the proposal is to establish a database to store information about goods imported into the EU. ILAB believes that extending this database to any kind of cultural goods, no matter the value, would put an excessive and unjustified burden on the shoulders of the booksellers and would create a risk of legal uncertainty for most common transactions.

In conclusion, I would like to remind you that here we are talking about printed books and manuscripts of European origin, which, if imported into the EU, are simply coming back home—a process that should be facilitated, including to protect European heritage, and not made unreasonably difficult.

The full proposal can be viewed here.

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