Has the EU’s cultural goods import regime achieved its aim?

This article examines the impact of the European Union's cultural goods import regime one year after its full implementation and considers whether it has succeeded in addressing illicit trade.

In Antiques Trade Gazette, Partner and Arts & Culture specialist, Fred Clark explores the practical challenges the regulations present for collectors, dealers and institutions dealing with historic cultural objects.

Fred discusses the difficulties created by requirements for provenance and export documentation dating back to the early 1970s, noting that many legitimately owned works entered private collections at a time when retaining such records was not common practice. He highlights the risk that objects with lawful ownership histories may face barriers to import into the EU simply because historic paperwork is unavailable.

The article also considers the broader effect of the regime on the international art market, including the increased compliance burden placed on legitimate participants and the potential for business to move to other jurisdictions. Looking ahead, Fred reflects on the growing importance of provenance and due diligence, while questioning whether the regulations have struck an appropriate balance between tackling illicit trade and supporting lawful ownership and collecting.

The full article was published by Antiques Trade Gazette (paywall) in August 2026.