Cultural goods compliance in 2026 for art freight forwarders: two directions, and the check that applies to both.

Written for art freight forwarders and logistics coordinators who move cultural objects into the EU, out of it, or both. Whether you already know the EU rules well or know your own country’s rules better than we ever will, this is our take on how the two sides fit together, and where we think we can help. The EU’s import regime has been in force since 2020, and its final piece, the licence and statement system, went live in June 2025. Exporting out of the EU runs on an older, separate regulation, and several member states add their own rules on top of both. Here is how it all connects, and what we would check before a shipment leaves.

Two directions, two sets of rules

Every cross-border move falls into one of two directions, and each draws on a different set of rules.

Bringing a cultural object into the EU means satisfying two separate regimes, the EU’s own import rules and the export law of the country the object is leaving. EU-based forwarders tend to know the import side well and have to chase down the origin country’s export law instead, often through a local partner or the consignor’s own counsel. Forwarders based outside the EU are usually in the opposite position. They know their own export rules well, and it is the EU import side this article sets out to explain.

Sending a cultural object out of the EU means satisfying the EU’s own export rules, plus, in several member states, an additional national layer that Regulation (EC) 116/2009 does not mention at all. Where the object is heading matters too, but mainly as a reminder to check the destination country’s own import rules directly.

Answering one question never answers the other. An export can require no paperwork at all to remain legal in its country of origin, and still call for an import licence or importer statement before the object can enter the EU. A shipment can be exempt from an EU export licence altogether and still be held up for lack of a national permit. Most rejected paperwork traces back to one of these two gaps.

Bringing a cultural object into the EU: Regulation (EU) 2019/880

Regulation (EU) 2019/880 sets the conditions for introducing cultural goods into the EU customs territory. Its general prohibition has been in force since 28 December 2020. The import licence and importer statement requirements followed later, applying since 28 June 2025, when the EU’s centralised electronic system for cultural goods went live. The regulation works in three tiers, taking into account the object’s category, age and customs value. Where a tier sets both an age and a value threshold, both conditions have to be met together. An object old enough but under the value threshold, or valuable enough but too young, does not trigger the requirement.

Tier one: the general prohibition

The regulation prohibits introducing into the EU any cultural good, falling within any of twelve broad categories (archaeology, ethnology, art, manuscripts and furniture over 100 years old among them), that was illegally removed from its country of creation or discovery.

There is no minimum age and no minimum value at this tier, and no exception for the customs procedure used. It applies equally to goods released for free circulation, goods placed under a special procedure, and goods merely in transit through the EU. A common mistake people make is to assume that temporary admission, customs warehousing or storage in a freeport somehow fall outside EU law, since the goods have not been released for free circulation. Those procedures defer duties and formalities, not the regulation’s reach. Enforcement is risk-based rather than systematic, but once a shipment is flagged, customs must act on it.

Tier two: the import licence

The import licence applies to archaeological excavation or discovery products, and to dismembered elements of monuments or archaeological sites, once they are more than 250 years old.

Importers submit the application through the EU’s centralised electronic system for cultural goods to the authority responsible for cultural goods in the member state of first import. That authority has 90 days to decide a complete application, with a possible 21-day request for further information and 40 days for the applicant to respond. Applicants should plan for that lead time, as this is not a document obtained the week before a flight.

Tier three: the importer statement

The importer statement covers the remaining categories (rare collections, historical property, antiquities such as coins and seals, ethnological objects, art, manuscripts, old books) once the object is both more than 200 years old and worth more than €18,000 in customs value.

The importer draws up the statement and files it with the customs declaration through the same system. No authority approves it in advance, which is exactly why the supporting evidence has to exist before the object ships.

Proving the object left its origin legally

Across all three tiers, the underlying question is the same. Was the object legally removed from its country of creation or discovery, under that country’s law as it stood at the time? Not today’s version of that law, and not the law of wherever the shipment happens to be coming from now.

Two fallbacks apply when that question cannot be answered directly. If the country of creation or discovery cannot be identified, or the object left before 24 April 1972 (when the UNESCO Convention took effect), the importer may instead prove legal export from the last country where the object stayed for more than five years. That country can itself be an EU member state, which makes a long-settled European provenance usable evidence.

The burden of proof rests with the importer in every case. Accepted evidence includes export permits, customs, insurance and transport documents, invoices, ownership titles, sworn declarations, expert appraisals, auction catalogues and dated photographs. We help clients organise and check that evidence against what the regulation requires, but assembling the invoices, the appraisals and the export paperwork from origin starts with the consignor and remains their responsibility, and yours as the forwarder handling the shipment. It is also worth telling a client that an import licence is not proof of ownership or provenance once granted, and that it can be revoked if the information behind it later turns out to be false.

The exemptions, and the one that matters at fair season

Five situations fall outside the licence and statement system:

• Cultural goods which were created or discovered in the customs territory of the Union.
• Returned goods re-entering the EU within three years of export.
• Temporary import for education, science, conservation, restoration, exhibition or research by a registered museum or similar institution.
• Goods sent by a third country’s public authority to an EU refuge, to prevent imminent destruction in a conflict or a disaster.
• Temporary admission for a commercial art fair.

For a temporary admission to a commercial art fair, an importer statement is sufficient even for an object that would otherwise require a full import licence. This simplification lasts only for the fair. If the object stays in the EU afterwards, most commonly because it sells to an EU buyer, the normal licence or statement rules apply from that point. It is worth planning for that possibility when you book the shipment, not after the fair closes.

Whatever the origin country requires before the object can leave in the first place is a separate question, governed entirely by that country’s own law. This article focuses on EU rules, so it is worth checking the origin country’s own export requirements directly, whether through your own knowledge of that jurisdiction, a local partner, or the consignor’s counsel. That check falls to you as the forwarder handling the shipment, and it is one of the places we are happy to help if you would rather not chase it alone.

Sending a cultural object out of the EU: Regulation (EC) 116/2009

Council Regulation (EC) 116/2009 requires an export licence for a cultural good leaving EU customs territory for a non-EU country, once the object falls into an Annex I category and passes the age and value threshold set for that category. There is also, in most cases, national legislation governing movement between member states, which the next section covers.

The table below simplifies the EU-wide Annex I thresholds down to their main age and value figures for each category. Annex I itself runs to finer sub-categories and cross-references that a summary table cannot show, so treat this as a working reference and check the full text for anything unusual.

Category	Age / value
Archaeological objects, monument elements	100 yrs / any value
Paintings	50 yrs / €150,000
Watercolours, gouaches, pastels	50 yrs / €30,000
Drawings, mosaics	50 yrs / €15,000
Prints, engravings, posters	50 yrs / €15,000
Sculptures	50 yrs / €50,000
Manuscripts, maps, scores	50 yrs / any value
Books	100 yrs / €50,000
Collections	no age limit / €50,000

The authority responsible for cultural goods in the member state where the object is lawfully and definitively located issues the licence, and this is a real constraint on the shipment rather than a formality. The object generally has to be physically present in that member state before the licence can be issued, so it can be presented for verification. This requirement also closes the loophole of moving a piece into a more permissive member state first, specifically to sidestep a stricter regime at its actual origin. Plan the shipment around wherever the object is physically located, not wherever it is registered, owned or invoiced from.

A licence remains valid for a fixed period from issue. For a temporary export (a loan, an exhibition), it can also specify the deadline for the object’s return.

Fortius can act directly when the object is physically in Luxembourg. We handle the export licence application with the competent authority ourselves, along with the customs interaction at Luxembourg Airport. When the object is located in another member state, we typically work through our own network of partners there. An EU-based forwarder may already be better placed to obtain that licence directly. A forwarder bringing us in from outside the EU can rely on us to coordinate the partner and the paperwork.

Once the object leaves EU customs territory, checking the destination country’s own import rules is on you or your partner at that end.

Country-specific rules inside the EU

Regulation (EC) 116/2009 governs export to non-EU countries only. It says nothing about moving a cultural object from one member state to another, and nearly every member state has separately legislated its own permit requirement for that movement, with its own categories, thresholds, or both. Several also layer an extra national requirement on top of the EU regime even for third-country export. Free movement of goods, the general EU principle, does not carry cultural property across an internal border on its own.

The four markets below cover most of what an art shipper handling EU business runs into. Thresholds move and get amended in each country’s own gazette without any EU-level announcement, so treat the figures as a starting point for a check, not the final word.

Germany

Germany’s Kulturgutschutzgesetz (KGSG), in force since 2016, requires a permit only once an object exceeds both the age and the value threshold for its category. Export to a non-EU country uses the Regulation (EC) 116/2009 figures directly, whereas export to another member state uses Germany’s own thresholds, generally around double the EU figures. A painting, for example, needs a permit for non-EU export past 50 years and €150,000, but for intra-EU movement the bar rises to 75 years and €300,000.

Two facilitations are worth knowing when shipping to or from Germany. An object legally imported into Germany and re-exported to the EU within two years needs no export permit at all, regardless of age or value, which helps with a piece that came in for a fair, a restoration or a loan. And a permit application must be decided within 10 working days, a considerably shorter wait than the 90 days allowed for an EU import licence.

Separately, an object individually registered as nationally valuable cultural property needs permission for any export, temporary or permanent, whatever its age or value. This status check is distinct from the threshold table above and worth raising before you book the move.

France

France requires its own export certificate, or a temporary exit authorisation, for any cultural good leaving French territory, whether the destination is another EU member state or a country outside the EU. This national document applies regardless of direction. Following a 2020 reform, its thresholds now run higher than the EU’s own Annex I figures for most categories, so an object can clear the French threshold and still need checking against the EU figures once it is heading outside the Union, where an EU export licence is required in addition to the French document, not as a replacement for it. An object registered, or being considered for registration, as a “national treasure” (trésor national, under Article L.111-1 of the Code du patrimoine) can only ever leave temporarily, with mandatory return, and a refusal of the export certificate on those grounds bars any new request for the same object for 30 months, during which the state may make an offer to acquire it. This is a different kind of risk than a missed threshold. An otherwise compliant, correctly valued shipment can still be stopped outright if the object is judged nationally significant, so it is worth checking for early rather than discovering it at the point of export.

Spain

Spain requires export authorisation for any object over 100 years old, or listed in its General Inventory of Historical Heritage Personal Property, regardless of value. This applies to both non-EU export and movement to another member state, which means that Spain has no separate, more lenient intra-EU threshold the way Germany does. Applications go to the relevant regional evaluation board, or the national one where the region has none.

The status check here is Bien de Interés Cultural (BIC). An object already declared BIC, or with a declaration in progress, can receive only temporary export authorisation, never a permanent one, for as long as the status stands.

Italy

Italy has recently reformed its rules, raising the protection threshold from 50 to 70 years and lifting the value floor for a full export certificate to €50,000 for works over 70 years old by a deceased artist. Below that value, a self-certification by the owner still needs checking by the export office before departure. This is a very recent change, so verify the current figures directly before quoting them to a client.

Italy’s own status check, “notifica”, a declaration of particular cultural interest, bars permanent export outright once made, regardless of age or value, and gives the state a right of first refusal on any sale. As in France and Spain, this stands alongside the ordinary threshold system rather than inside it, so it needs its own check.

What we can do, and what stays with you

We flag the national-treasure-style risk in these four countries as part of reviewing a shipment, and for applications that go through Luxembourg, we handle them directly. For an application that has to go through another member state’s own authority, we work it through our own partner network there, and an EU-based forwarder may already be better placed to obtain that permit directly. What we do not do is make the classification call, that means whether a specific piece counts as a trésor national, a BIC, or a notifica. That determination is the responsibility of the country’s own authority and the client’s own advisers, and it is worth raising early rather than at the point of export.

CITES ignores cultural value entirely, in both directions

CITES runs on an entirely different logic from the cultural goods rules above. It looks at an object’s material, not its type, age or value. The two sets of rules are separate from one another, and depending on the object, they can apply jointly or independently, so it is worth keeping them apart in your thinking regardless of which direction a shipment travels.

Any object containing animal or plant material from a protected species falls within its scope. Common examples include tropical hardwood in a frame, a stringed instrument, ivory inlay on a cabinet, leather, and a crocodile-skin strap on a design piece. A certificate is required whatever the object’s cultural value, and it is entirely separate from any cultural goods licence or statement. A shipment can clear every threshold in this article, in either direction, and still be stopped over its materials.

Check the species on cites.org before assuming a piece travels clean, and get the certificate into the shipment’s paperwork early. We issue and process CITES certificates alongside the rest of the customs documentation.

How the steps line up for a shipment routed through Luxembourg Airport

The steps below help you avoid rework, whatever direction the object is moving. Start by establishing where it was created or discovered, and what provenance evidence exists, since everything downstream depends on this.

• In case of an export, clear the national exit first, then the EU export licence where the object needs one. The national licence has to be in hand before the European one.
• When importing into the EU, handle the import side at destination, whether that is a licence, an importer statement or an exemption, with the general prohibition confirmed separately in every case.
• Check for a CITES requirement independently of the above, since it depends on the object’s materials rather than its cultural status.

For works located in Luxembourg, we obtain the European export licence through the competent authority ourselves. We also manage licences issued in other member states, present them to customs and discharge them before departure. On transit, we issue the T1 or manage and discharge the document you provide. Where artworks travel under an ATA Carnet, we check the Carnet and present it to customs for signature and stamping. We also keep the Carnet with the shipment throughout, or send it ahead by courier to its final destination for clearance. Our team filed 213 transit documents at Luxembourg Airport in 2025, and the full document list is on the Customs & Cultural Goods page.

One honest caveat. Thresholds move, national categories get amended, and several member states are still not documented in the comparison tables the industry works from. Everything above should help you ask the right questions and obtain the necessary documentation and information for your transport. On a real shipment we verify the current text before we advise, and anyone advising you should be doing the same.

Customs alone, if that is all you need

Customs and cultural goods is a standalone service in our toolkit, not a bundle. You can hand us the customs formalities, keep the transport with your own carriers, and keep your client relationship entirely to yourself. This service is designed to complement the package you offer your own client, not to compete with it. In 2025 we handled around ten cultural goods and CITES shipments, all types together.

If you want eyes on the crates as well, supervision is a separate service. The step-by-step of an import or an export operation is in our supervision guide and on the Airport Supervision page. Export screening is separate again, with the three methods compared on the Freight Securing page. And the structural reasons art moves through this airport, Cargolux included, are detailed in our article on “Why fine art moves through Luxembourg.”

A note on everything above. Every figure, threshold and legal reference in this article was accurate at the time of writing but cultural-goods law changes, in more than one country and at more than one level, without much notice. Treat this as a map, not a ruling. If you have an actual shipment to check against the current rules, that is exactly what the box below is for.