This mail concerns the EU questionnaire about possible future measures to
prevent illicit import from "cultural goods" into the EU. This
questionnaire applies to all cultural goods imported from outside Europe,
not just antiquities and will affect the European art and antiques trade
It is extremely important for as many dealers as possible to respond to
the survey, including with critical remarks. We know that Europe will make
statistics from the answers, therefore the more art dealers react, the
more influence we have on the outcome.
It is possible to do it anonymous, but we think it's better under your own
name. UK colleagues are, in spite of (possible) future Brexit, also
requested to complete the survey. PLEASE DO IT TODAY, YOUR FUTURE IS
DEPENDING ON IT. (ultimate deadline is January 23rd)
Despite letters explaining to the EU authorities why the questionnaire is
invalid and ill informed, they have disregarded all suggestions, resulting
in an impossible survey. We have attached the remarks / position paper
about the survey, as submitted by our colleagues from the IADAA, the
International Association of Dealers in Ancient Art. (CINOA will submit a
response to the survey as part of the European Art Market Coalition which
is still finalising their answers).
We have also attached the filled in questionnaire as suggested by the
IADAA, which you can use as a guideline to save time. With the help of the
answers provided it should take not more than half an hour. Below and
attached you will find their analysis and recommendations.
Bear in mind that some questions are traps that should not be answered at
The main problematic issues are:
1) the EU assumes a large illicit trade in cultural goods (that has not
2) The EU assumes (massive) terror financing though there has not been a
single proven case in 4 years.
(INTERPOL and EUROPOL acknowledge that)
3) They do not define "cultural goods", so the answers cannot be compared
and or compiled.
This alone makes the complete exercise useless.
Please propose to use the definition for "cultural goods" as defined by
UNESCO 1970 Art.1:
"important cultural property which, on religious or secular grounds, is
specifically designated by each State as being of importance and whose
export would constitute an appreciable impoverishment of the national
For your convenience find here the links to the survey in English, French,
German and Italian. The survey is available in all European languages.
If you have any questions, do not hesitate to contact us or our colleague,
Vincent Geerling, chairman of the IADAA, firstname.lastname@example.org
, who has
provided us the majority of the content for this message.
We thank you in advance for completing the survey,
For more information: www.cinoa.org
Attachment 1: here
Attachment 2: here