Selling to the EU: Regulation 2019/880

Regulation (EU) 2019/880 on the introduction and the import of cultural goods has applied in full since 28 June 2025. It has three parts. Part A is a general prohibition: cultural goods removed from the country where they were created or discovered in breach of that country's law may not be brought into the EU at all. Part B lists the goods that need an import licence from a member-state authority before entry — archaeological objects from excavations and finds on land or under water, and elements of monuments that have been dismembered — when they are more than 250 years old, with no value threshold. Part C lists goods that need only an importer statement — a self-declaration filed with customs — when they are more than 200 years old and worth €18,000 or more.

Both the licence and the statement are filed through the ICG electronic system, which is integrated with the EU Single Window for Customs; the applicant must show that the goods were lawfully exported from the country where they were created or discovered, or lawfully exported from the last country in which they were held for more than five years for purposes other than temporary use. Exemptions cover goods returning to the EU, goods in transit, and goods imported for exhibition, restoration, research or education.

For a Stratum seller this is a buyer-side rule: a dealer in Ohio does not need the licence, but the buyer in Munich cannot clear customs without the seller's documents. Stratum raises a warning on any lot with an end date before 1776 that the seller ships internationally, so the export certificate, the pre-restriction provenance or the customs entry are gathered before the sale, not after. Germany's own Cultural Property Protection Act (KGSG 2016) adds due-diligence duties on dealers importing to Germany.