European Commission Call For Evidence On The Initiative: A Cultural Compass For Europe
Date: Submitted on May 22, 2025

Submitted by: CINOA – Confédération Internationale des Négociants en OEuvres d’Art www.cinoa.org

CINOA, the international federation representing 5,000 art and antiques dealers through 32 organisations across 22 countries, welcomes the European Commission’s consultation as part of its review of cultural policy.
We strongly support the objective of embedding culture more deeply into EU policy and external action. In doing so, it is essential to recognise the vital contribution of the art and antiques trade to the European cultural ecosystem.

Micro and small businesses (M-SME) in this sector—such as galleries, dealers, auction houses, antiquarian booksellers, restorers, appraisers, and other cultural intermediaries—play a vital role in promoting culture and historical knowledge, supporting the circular economy, and embodying the European Way of Life. They also act as key facilitators of public access to cultural objects, often working with living artists, to encourage cross-border cultural exchange and ensure the preservation and transmission of cultural heritage.
CINOA answers to this call of evidence to present our priorities and recommendations for an inclusive EU cultural strategy. Download our submission.

Key recommendations for the Culture Compass for Europe
CINOA stands ready to engage proactively with EU institutions to ensure that the voices and needs of the art and antiques trade are fully reflected in future cultural policy. We urge the European Commission to advance the concrete proposals outlined in this submission, which will help equip micro cultural actors to meet regulatory obligations, uphold the integrity of the internal market, and strengthen the EU’s leadership in cultural preservation, circulation, and international engagement.

To ensure a robust and inclusive EU cultural policy, CINOA proposes that the Cultural Compass:
• Recognises the vital role the art and antiques trade including auction houses and antiquarian booksellers plays in preserving Europe’s cultural heritage and supporting sustainability, cross-border exchange, and the EU’s green and circular economy goals — and that it be formally acknowledged as such.
• Ensures proportionality, evidence-based policymaking, and sectoral representation in all cultural and market-related EU measures.
• Supports and recognises in EU policy, the sector’s micro and small businesses (M-SMEs). Those actors face disproportionate regulatory burdens and barriers to funding and participation which should be addressed by the European Commission.
• Encourages targeted, simplified support mechanisms and dedicated resources within EU cultural programmes to empower these M-SME actors as part of a vibrant, inclusive, and competitive cultural economy.
• Develops recommended EU-level minimum criteria and procedural safeguards for the “national treasures” exemption under Article 36 TFEU to protect free movement while safeguarding legitimate national heritage.