Revised on 20 October 2026. This guide is for information purposes only. Should you identify an error, please contact me.
Since 28 June 2025, the import of certain cultural goods created or discovered outside the customs territory of the Union has been processed via the ICG electronic system. Regulation (EU) 2019/880 establishes a general prohibition and, for some categories, a licence or an importer declaration.
1. The general prohibition
Cultural goods that have been illicitly removed from the country where they were created or discovered may not be introduced into the Union. This rule is independent of price. The fact that an item is sold legally in the final country of transit does not demonstrate that it left its country of origin legally.
The Regulation provides for exceptional cases in which lawful export from another country may be proven, for example, if the country of creation or discovery cannot be reliably determined. It is not advisable to apply these exceptions without reviewing Article 4 and the specific history of the object.
2. Import licence
Required for:
- Archaeological objects.
- Elements forming an integral part of artistic, historical or religious monuments or archaeological sites.
They must be at least 250 years old. There is no economic threshold. The competent authority examines the evidence of lawful export before granting the licence.
3. Importer declaration
For the categories in Part C of the Annex, a declaration is required when the item is more than 200 years old and has a value equal to or greater than 18,000 euros per object. This includes, according to the definitions in the Annex, paintings, sculptures, engravings, manuscripts, books, photographs, collections and other goods.
The declaration contains two elements: the statement, under the importer's responsibility, that the good was exported lawfully, and a standardised description that allows for its identification. It is not a mere customs box. It must be supported by documents that can be preserved and are linked to the item.
4. Documentation to be prepared
Depending on the good and its history, the following may be relevant:
- Export permits or certificates from the country of origin.
- Invoices, contracts, titles of ownership and succession documents.
- Customs, transport and insurance records.
- Historical photographs, publications and catalogues.
- Expert reports and provenance documentation.
A seller's statement does not rectify a broken chain of provenance. If the item lacks a verifiable history, apply the due diligence described in Restitution and responsible acquisition and in Provenance of a work of art.
5. Exemptions and temporary uses
Returned goods are not subject to a licence or declaration under the conditions provided for by the Regulation. Nor are certain temporary imports for educational, scientific, conservation, restoration, exhibition, digitisation, performing arts, institutional research or museum cooperation purposes.
At trade fairs, a temporary import of a good that would normally require a licence may be processed initially with an importer declaration; if the good remains in the Union after the fair, the licence must be obtained. Do not confuse this exception with a general exemption for the art market.
6. Three cases
- Painting from 1790 purchased in the United States for €40,000. If it was created outside the EU, it exceeds the age and value limits of Part C: it requires a declaration.
- Archaeological ceramics 2,000 years old purchased for €800. It requires a licence even if its value is low.
- Engraving from 1900 valued at €25,000. In 2026 it does not exceed 200 years of age: it does not require these documents, but it remains subject to the general prohibition if it was exported illicitly.
7. Who is involved
The application and the declaration are managed electronically in ICG. The competent cultural authority examines the licences and customs controls the import. In Spain, the Ministry of Culture and the Tax Agency intervene within their respective competencies.
Checklist
- I have confirmed that the good was created or discovered outside the EU.
- I have identified its exact category in the Annex.
- I can prove its age and value.
- If it requires a licence, I will not import it before obtaining one.
- If it requires a declaration, I will retain the evidence that supports it.
- I have reviewed whether a temporary exception truly applies.
- If the provenance is insufficient, I will halt the operation.