[Nhcoll-l] URGENT ALERT: final entering in to force of EU cultural heritage law severely impacts specimen import and export of specimen to the EU and within Europe (CH/NO/IS)

[Dirk Neumann]

Dear all,

[Please circulate and share this message widely in the community, as all institutions shipping or receiving cultural goods are affected, specifically all 'palaeo sciences's, i.e. archaeology, anthropology, zooarchaeology, ethnography, libraries etc.]

last Friday, on 28 June 2025, the new EU regulation (EU) 2019/880 on the introduction and import of cultural goods entered fully into force.

This surely well-intended regulation aims to counteract the illicit shipping and import of cultural goods. It regulates any object shipped, declared and imported under the harmonised customs Tariff code 9705.

Art. 3 stipulates that

the introduction of cultural goods referred to in Part A (see at the end of this email) of the Annex which were removed from the territory of the country where they were created or discovered in breach of the laws and regulations of that country shall be prohibited.

Art. 4 exempts cultural goods listed in Parts B and C of the annex, which is basically any cultural good under HS-code 97 (Chapter 97) that

  *   are less than 200 years old
  *   have a monetary value of less than 18,000 EUR

Since last week several Natural History Collections report that they have issues with shipments being stuck at customs to clarify the status of their "cultural goods" or if "art" would be included.


We should thus anticipate problems and try to adjust our templates and procedures as follows:

1. Imports from the Afrika/Americas/Asia/Australia to the EU / European

  *   avoid sending materials through national postal services and prefer FedEx, US or DHL Express
  *   continue to use HS 9705 and choose the correct subchapters for your materials (see below or check PDF-page 632 in the EU customs codex (EU) No 861/2010<https://eur-lex.europa.eu/legal-content/DE/ALL/?uri=CELEX:32010R0861>)
  *   make sure you have a proper customs declaration attached to the outside of the consignment (no proforma invoices etc.)
  *   add the following statements to your shipping doc templates

This package contains dead museum specimens (preserved dried insects; paratypes of xxx xxx; holotype of xxx xxx) for scientific research, which are exclusively exchanged between museums acc. point (5) (b) in the Annex of Commission Regulation (EU) 2020/762 amending (EU) No 142/2011. The material was originally fixed with ethyl acetate and/or are have been treated with pure ethanol (> 96 %) for preservation. Theses specimens are non-infectious, non-contagious, non-venomous and unfit for human consumption. Preservation agrees with requirements for SAFE TREATMENT laid down in Point (8) (a) (d) in the ANNEX to the Commission Regulation (EU) No 294/2013, amending Commission Regulation (EU) No 142/2011, ANNEX XIII, CHAPTER VI. The package does not contain endangered species or listed cultural goods that requires an import or export permission acc. to Art. 4 n regulation (EU) No 2019/880. The specimens packed were on loan to the xxx Institute/Museum for biodiversity (morphological / taxonomical) research and are legally owned by the Institute/Museum (Country of Origin: xxx); they are non-infectious, non-contagious, non-venomous, unfit for human consumption, no traded goods, have no commercial value and are not for resale.


               HS-Code:              9705 29 00 (Collections of zoological / botanical / mineralogical
                                                                                      paleontological interest, not extinct or endangered, no regulated cultural goods)
                Declared value:  1.00 €

These specimens do not contravene the UNESCO 1970 Convention or Art. 4 in regulation (EU) No 2019/880 on the means of prohibiting and preventing the illicit import, export and transfer of Ownership of cultural property.



We are currently trying to address the issues and to find ways to approach the EU Commission, however, changes or amendments may not be in place for the next weeks.


Please report any issues trouble on this list or email me directly; we are currently collecting cases to address this with the EU Commission.

With best wishes

Dirk


***

Part A

(a) rare collections and specimens of fauna, flora, minerals and anatomy, and objects of palaeontological interest;
(b) property relating to history, including the history of science and technology and military and social history, to the life of national leaders, thinkers, scientists and artists and to events of national importance;
(c) products of archaeological excavations (including regular and clandestine) or of archaeological discoveries on land or underwater;
(d) elements of artistic or historical monuments or archaeological sites which have been dismembered (1);
(e) antiquities more than one hundred years old, such as inscriptions, coins and engraved seals;
(f) objects of ethnological interest;
(g) objects of artistic interest, such as:

(i) pictures, paintings and drawings produced entirely by hand on any support and in any material (excluding industrial designs and manufactured articles decorated by hand);
(ii) original works of statuary art and sculpture in any material;
(iii) original engravings, prints and lithographs; (iv) original artistic assemblages and montages in any material;

(h) rare manuscripts and incunabula;
(i) old books, documents and publications of special interest (historical, artistic, scientific, literary, etc.) singly or in collections;
(j) postage, revenue and similar stamps, singly or in collections;
(k) archives, including sound, photographic and cinematographic archives;
(l) articles of furniture more than one hundred years old and old musical instruments.
(1) Liturgical icons and statues, even free-standing, are to be considered as cultural goods belonging to this category.

[cid:part1.Q9UugJfM.u6r0FaII at leibniz-lib.de]

--
****

Dirk Neumann
Collection Manager, Hamburg

Postal address:
Museum of Nature Hamburg
Leibniz Institute for the Analysis
of Biodiversity Change
Dirk Neumann
Martin-Luther-King-Platz 3
20146 Hamburg
+49 40 238 317 – 628
d.neumann at leibniz-lib.de<mailto:d.neumann at leibniz-lib.de>
www.leibniz-lib.de<imap://dneumann@webmail.leibniz-lib.de:993/fetch%3EUID%3E/INBOX/Privat/www.leibniz-lib.de>

--
Stiftung Leibniz-Institut zur Analyse des Biodiversitätswandels
Postanschrift: Adenauerallee 127, 53113 Bonn, Germany

Stiftung des öffentlichen Rechts;
Generaldirektion: Prof. Dr. Bernhard Misof (Generaldirektor), Adrian Grüter (Kaufm. Geschäftsführer)
Sitz der Stiftung: Adenauerallee 160 in Bonn
Vorsitzender des Stiftungsrates: Dr. Michael Wappelhorst

--
Stiftung Leibniz-Institut zur Analyse des Biodiversitätswandels
Postanschrift: Adenauerallee 127, 53113 Bonn, Germany

Stiftung des öffentlichen Rechts;
Generaldirektion: Prof. Dr. Bernhard Misof (Generaldirektor), Adrian Grüter (Kaufm. Geschäftsführer)
Sitz der Stiftung: Adenauerallee 160 in Bonn
Vorsitzender des Stiftungsrates: Dr. Michael Wappelhorst
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