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Mark Dodgson, secretary general at the British Antique Dealers’ Association (BADA), described proposals as “a case of taking a sledgehammer to crack a nut”.

The European Commission recently launched a new survey, saying it was considering introducing “customs measures” that include “a strict requirement to obtain an EU licence before any import”.

The questionnaire, titled Consultation on Rules on the Import of Cultural Goods, follows an initial longer document that was issued earlier this year. They form part of the commission’s efforts to fight illicit trafficking of artefacts from war-torn countries. As reported in ATG, a separate UK bill – the Cultural Property (Armed Conflicts) Bill – is currently moving through Parliament.

The extent of the illicit art problem is a moot point. Dodgson added: “This consultation provides no meaningful evidence about the precise problem that needs to be solved, nor is there anything to indicate how frequently illegally exported objects are entering the EU.”

All Cultural Objects

Dodgson said that although the EU’s focus appears to be on antiquities, import licences could “apply to all cultural objects including paintings, jewellery and furniture”.

In the hope of highlighting its concerns, the BADA is encouraging members to complete the questionnaire, as is LAPADA, the Society of London Art Dealers (SLAD) and the British Art Market Federation (BAMF).

New EU import licences would be a layer of red tape that could impact all dealers and auctioneers trading with Europe – even after Brexit.

Anthony Browne, chairman at BAMF, said: “This [consultation] came out of concerns around the funding of terrorism but unfortunately it is a very bureaucratic response to a specific problem.

“The option of import licences would be hugely burdensome for our market.”

Christopher Battiscombe, director general of SLAD, said the consultation “could end up with sweeping new regulations which would risk doing serious damage to the whole of the EU art trade”.

Dealer Vincent Geerling (Archea Ancient Art), chairman of the International Association of Dealers in Ancient Art, described the consultation as a “secret” that few were aware of.

He urged the commission to provide a clearer definition of  the term cultural property and added: “We don’t need these regulations. New import restrictions will not help. It will only hamper legitimate trade and the illegal trade will carry on.”

The consultation is open until January 23.