EU Import Licence Rules for Art & Antiques (2025)

This change may impact how dealers, collectors, museums, and logistics providers handle shipments, especially for older or high-value works.

Here’s what’s changing, what’s required, and how to keep your shipments moving.

Why this regulation now?

Until the update, the EU only regulated the export of cultural goods. Imports, on the other hand, went largely unchecked. That changes with the new Import of Cultural Goods (ICG) regulation, which is designed to combat the trafficking of looted or illicitly exported cultural property.

The core idea is that EU importers are now responsible for ensuring that any cultural object entering the Union was lawfully exported from its country of origin.

The regulation introduces three categories:

• Part A: General prohibition of illicit cultural property
• Part B: Import licence required
• Part C: Importer statement required

Only Parts B and C require administrative action. Let's look at each one.

Need help navigating the ICG portal or determining if your item qualifies? Contact our team today.

Part A: What’s banned outright

Before we talk about what paperwork is needed, it’s important to understand what’s completely prohibited.

The general prohibition known as Part A is against importing cultural goods that were illegally removed from their country of origin. No paperwork is required for this section because such goods simply cannot be imported under any circumstances.

In other words:

“The introduction of cultural goods (…) 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.”

It’s a broad rule with no age or value threshold. It underlines the EU’s core aim: stopping the trafficking of looted cultural property.

Due diligence

If a cultural good is allowed into the EU under Part A, it may still require documentation under Part B or Part C, depending on age, value, and origin:

Let’s break down each pathway.

Part B: Import licence required (250+ years)

For cultural goods over 250 years old:

This applies only to specific categories of cultural goods, namely archaeological objects and elements of monuments or sites of historical interest, as defined in Annex I, Part B of the regulation.

This does not apply to paintings, furniture, manuscripts, or other types of cultural goods, even if they exceed 250 years in age.

Key Conditions:

• Originating from outside the EU
• 250 years or older
• No minimum value threshold

Annex I, Part B covers only:

• Archaeological objects more than 250 years old
• Integral parts of monuments, buildings, or archaeological sites with historical or ethnographic value

Who applies:

The importer or their authorized representative (e.g. customs broker) via the ICG portal before customs clearance.

The process:

• Submit application via the ICG portal
• Wait for review by the national authority (e.g. Service des Musées de France)
• Receive reference number and downloadable licence PDF
• Include both in customs declaration:
  • Document code: L049
  • Licence reference number

Estimated processing time: 30 working days (may vary depending on the country)

Example: Part B A Roman marble bust from Syria, dated 2nd century AD, being imported into France. Even if it was purchased for €3,000, a Part B Import licence is required because the item is over 250 years old and from outside the EU.

An application has to be submitted via the ICG portal, and once approved, a licence reference number and PDF will be issued. These must be included in the customs declaration using code L049.

Part C: Importer statement (200+ years and EUR 18,000+)

For cultural goods over 200 years old and valued over €18,000:

This applies to a wider range of cultural goods, including manuscripts, paintings, and antiques, that meet both the age and value thresholds.

Article 4(2):

The importer shall submit an importer statement [...] certifying that the cultural goods have been exported [...] in accordance with its laws and regulations.

Key conditions:

• Only the importer may submit the declaration
• The declaration affirms the lawful export of the item
• It must be submitted via the ICG portal before customs

Who applies:

• Only the importer. This cannot be delegated to a shipper, broker, or forwarder.

The process:

• Create an account on the ICG portal using your EORI number
• Submit the importer statement and supporting documents
• Receive declaration reference number and PDF
• Include both in customs declaration:
  • Document code: L050
  • Declaration reference number

Example: Part C

A 19th-century oil painting from the US, valued at €25,000, being imported into Germany. The piece is over 200 years old and exceeds the €18,000 threshold, so it requires a Part C Importer Statement.

The importer logs into the ICG portal, submits the self-declaration, and receives a reference number and PDF. These are then included in the customs declaration using code L050.

Need help determining if your item meets the threshold? Contact our team for a compliance check.

So, who can submit what?

This distinction is critical. If the wrong party submits (or fails to submit), the shipment may be delayed or rejected at customs.

Can you still use DHL, FedEx, or UPS?

Yes, major carriers can still be used under both procedures as long as the required documentation is prepared before shipping.

Conditions:

• Part B (import licence): share licence reference and PDF with the carrier (customs code L049)
• Part C (importer statement): share declaration reference and PDF with the carrier (customs code L050)

What Convelio’s team is doing

As of June 30th, our EU team reviews every inbound shipment to the EU, something we previously only did for exports.

If we identify an item that may require documentation, we’ll contact the relevant account manager or client coordinator before dispatch to assist with the licence or declaration process.

This is a complex rollout, we’re closely monitoring how national authorities and the ICG portal handle early applications.

Working with us means you’ll always be notified early if your shipment qualifies under Parts B or C.

What you should do right now

• Check the age and value of your piece
• Determine if a Part B or C procedure applies
• Ensure the importer has an EORI number
• Start the ICG process early especially if a licence is needed
• Reach out if you need help determining eligibility, gathering documents, or submitting declarations

For contemporary pieces and modern art: nothing changes, shipments proceed as usual.

Our Customs team is actively reviewing all incoming shipments bound for the EU. If your piece may be subject to the new regulation and we’ll reach out proactively to support you with licensing or declaration requirements.

Final Thoughts

The new EU regulation brings the art market in line with international standards for provenance and legality, but also introduces new responsibilities for importers.

If you deal in cultural goods over 200 years old, now is the time to get familiar with the ICG portal, EORI registration, and customs documentation workflows.

We’re here to help you ship compliantly and confidently.

Have an upcoming shipment? Get an instant quote today.