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EU Import Regulation No 2019/880

Import of Cultural Goods

Since June 28, 2025, the import of certain cultural goods from third countries into the customs territory of the European Union has been subject to authorization or declaration. The Federal Art Administration has been the central contact point for import procedures of cultural goods from third countries into the Federal Republic of Germany being the competent authority for issuing import licences pursuant to Article 4 of Regulation (EU) 2019/880.

Regulation (EU) No 2019/880 of the European Parliament and of the Council of 17 April 2019 on the introduction and the import of cultural goods

Scope of the Regulation

The EU Import Regulation applies exclusively to cultural property originating outside the European Union. Cultural goods which were created or discovered in the customs territory of the Union and which return to Europe do not fall within the scope of the Regulation. The types of cultural property that are covered by the Regulation are listed in the annexes of the EU Import Regulation determining the respective import procedure.

A graduated system of measures

The EU Import Regulation provides for a graduated system of measures, consisting of:

  • total prohibition of the introduction of cultural goods that were illegally removed from their countries of origin, whatever their age and value (Article 3(1) in conjunction with Part A of the Annex to the Regulation);
  • an import licence requirement for archaeological cultural goods and elements of historic monuments, whatever their value but more than 250 years old (Article 4 in conjunction with Part B of the Annex to the Regulation); and
  • an importer statement for other categories of cultural goods classified as less endangered, more than 200 years old and with a value of more than EUR 18,000.

Both the import licensing procedure and the importer statement require action on the part of the importer and must be completed before the property clears customs. Applications on import licences according to Article 4 of the EU Import Regulation must be submitted electronically to the Federal Art Administration. Importer statements in accordance with Article 5 of the EU Import Regulation can be issued independently by the importer using the electronic system. Details of the procedure are set out in the Implementing Regulation.

Criterion of lawful import and relaxation of procedures

The EU Import Regulation applies the country of origin principle customary in matters relating to the protection of cultural property, i.e. in order for cultural goods to be imported lawfully into the EU, they must have been lawfully exported from their country of origin (not from the country of export, which may be different). However, in certain cases, the Regulation grants exceptions to this rule and allows lawful export to be assessed by reference to the law of a country of export which is not the same as the country of origin.

These exceptions cover the following cases:

  • country of origin unknown; and
  • goods exported from the country of origin prior to the entry into force of the UNESCO Convention, i.e. before 24 April 1972.

In both cases, however, proof must be provided that the cultural property in question has been in the relevant country of export for at least five years. The purpose of this last provision is to prevent exporters from deliberately choosing a country with a weak legal system and exporting goods to the EU from there.

Legal bases