U.S. CPAC Meeting February 4–6, 2025 on import restrictions on archaeological and ethnological materials for Vietnam, Chile, Italy, and Morocco.
Subject: Cultural Property Advisory Committee (CPAC) Meeting on February 4–6, 2025: A request from the Government of the Socialist Republic of Vietnam seeking import restrictions on archaeological and ethnological materials, the proposed extension of the agreement with the Government of the Republic of Chile, with the Government of the Italian Republic, and with the Government of the Kingdom of Morocco. (The meeting was postponed without providing a future date)
Comments from CINOA, the Principal Federation of Art and Antique Dealing Organizations Worldwide
CINOA, representing 5,000 art and antique dealers and auction houses globally and advocating for responsible trade with a focus on cultural conservation and the trade’s role in preserving, protecting, and supporting cultural heritage, expresses grave concerns about the proposed extension and expansion of Memoranda of Understanding (MOUs) under review at the upcoming CPAC meeting:
Key Concerns
- Sweeping and Unwarranted Import Restrictions
These MOUs risk imposing sweeping and unwarranted import restrictions on a wide range of cultural artifacts, including Roman Republican and Imperial coins, ceramics, tools, sculptures, and other archaeological and ethnological materials. The propose restrictions are on widely distributed items that are not unique to these nations. Such broad measures undermine international collaboration and risk setting an unsustainable precedent.
- Wide Distribution of Artifacts and Coins
Many artifacts , including Roman Republican and Imperial coins, were mass-produced and circulated widely across Europe, the Mediterranean, and beyond. These items do not meet CPIA’s requirement of being “first discovered within” and “subject to the export control” of a specific nation, making their classification as exclusive cultural property both inappropriate and impractical.
- Violation of CPIA’s Original Intent
The CPIA was never designed to restrict the movement of common, widely distributed artifacts like coins or tools. Targeting such items reflects a significant and unjustified overreach. - Legality of Trade in Source Countries
Many items targeted by these MOUs, including Roman coins, are legally owned, traded, and sold in their countries of origin, such as Italy. Restricting their import unfairly penalizes American collectors, researchers, and institutions while failing to achieve CPIA’s goals. - Impact on Research and Public Access
Broad restrictions impede legitimate collecting and scholarship, depriving academics and the public of access to vital elements of cultural heritage. Narrow, targeted measures would better protect heritage while enabling continued research and cultural exchange.
Italy
- Premature Action
The MOU with Italy, for example, does not expire until 2026. Expanding restrictions now is unnecessary, especially given significant reductions in looting due to robust enforcement in source countries.
Global Impact
- The Consequences of Overly Broad MOUs
Over extensive MOUs jeopardizes legitimate trade, scholarship, and public engagement without substantially improving cultural preservation. Artifacts such as coins, tools, and ceramics, widely traded and studied for centuries, were never intended to be restricted under the CPIA. Overreach in this context damages international relations, undermines transparency, and unnecessarily limits access to our shared global heritage.
Conclusion
CINOA strongly urges CPAC to:
- Reject overly broad restrictions on mass-produced and widely distributed artifacts.
- Prioritize narrowly tailored measures targeting items genuinely at risk of looting or trafficking.
- Respect the original intent of the CPIA, ensuring that restrictions support cultural preservation without impeding legitimate trade, research, or public access.
The future of fair and balanced cultural property agreements depends on addressing these issues decisively. We urge CPAC to act to protect not only cultural heritage but also the rights of collectors, researchers, and the global public.
Thank you for your attention to this critical matter.
The CINOA Secretariat