Collecting jewellery

What do the EU-rules on cultural goods mean for me?

Published June 25, 2025

Rules and conventions that affect how you collect jewellery keep on changing, so here is a new blog on a new set of rules! From June 28, 2025, a new European Union law – Regulation (EU) 2019/880 – is in full effect. And if you’re a collector of Middle Eastern jewellery, or someone who sells it internationally, this regulation actually matters. So I’d thought I’d give you the main breakdown of when and why this matters to you!

The main point: you can’t import ancient beads or jewels into the EU without an import licence and sound provenance. Details, exceptions and what to do as either a buyer or seller are in this blog.

Before we start, again a disclaimer up front: I’m a jewellery historian, not a lawyer. But I would like to give you a heads’ up on this development, so you know this exists.

Let’s see how this works!

What is EU Regulation 2019/880 on the import of cultural goods?

This one is not about modern trade tariffs or commercial sales tax. It’s about something deeper: cultural heritage. This regulation governs the import of cultural goods into the EU and is designed to stop the illegal trade of cultural items – especially those removed from their countries of origin during times of conflict or without permission.

This EU-wide regulation sets rules for how cultural goods can legally be brought into the EU from non-EU countries. Its goal is to:

• Prevent looted or illegally exported cultural items from entering the EU.
• Protect cultural heritage, particularly from countries affected by conflict.
• Create a more uniform and transparent system for imports across EU countries.

This is not a new idea: international conventions have been calling for this kind of protection for years. But this is the first time the EU has set up a unified legal framework to enforce it at the border. And as such, this regulation is a gamechanger for many businesses.

How Regulation 2019/880 affects jewellery collectors

If you collect traditional jewellery from North Africa and the Middle East, Regulation 2019/880 probably will not have that much effect. Because after all, there is not that much traditional jewellery that is older than 250 years and that meets the value threshold of the regulation (which I will go into below).

But there are implications for one particular category, and that is why I chose to devote a blog to it. Many old beads, especially those labelled as archaeological, dug-up, or ancient, fall under this regulation. Those are the kind of beads that you will often find in modern designs, and that are avidly collected by jewellery collectors and designers alike. So, if you are selling trade beads and also include ancient beads in your offerings, or designing new jewellery pieces from ancient components, selling these to customers in the EU requires your attention. Even if they’ve been in circulation for decades.

Which jewellery counts as a ‘cultural good’?

So, what is a cultural good? The regulation follows a specific definition of cultural goods. That is a different definition than UNESCO 1970 or the CITES-definitions: I can’t help that, but here we are.

See more about UNESCO 1970 here

See more about CITES here

The definition of cultural goods includes objects of archaeological interest that are over 250 years old. It doesn’t matter how small or unassuming the item is.

So yes: ancient beads, dug-up items, grave goods, or antique adornments that have archaeological origins fall into this category. Jewellery that has been excavated, or that is believed to come from historical sites, even if it’s only a strand of stone or glass beads, may be covered by the regulation.

Still wondering if that affects you? Have a look at these terms, often found on auction platforms, Ebay or Etsy stores:

Saharan ‘Neolithic’ beads. Mummy beads. Sassanian seals. Roman glass beads. Nila beads. Carved seals and intaglios. Ancient Egyptian faience amulets. Islamic glass beads. Etched carnelian beads. Roman/Islamic glass bangles. Ancient melon beads.

Any of these look familiar, or like something you’d buy or sell? That’s when you need to be aware of this regulation on cultural goods. And just to be clear: obviously, I know that many of these items have been above ground for a very a long time. I am also aware that many of these are actually fake or, at best, misrepresented recent productions. In fact, I even can’t help but wonder if we will be seeing a whole lot less of those presumably ‘archaeological’ items, now that these regulations are in place.

But on the other hand… the Sahara is still being robbed of its beads today, as are grave sites on various locations. The point of the regulation is to prevent the illicit trade in those items – and the legislators have chosen to create a definition that includes everything.

Categories of cultural goods: what collectors should know

There are different categories of cultural goods under this regulation. The most relevant for collectors and traders of older jewellery include:

Category B: Objects older than 250 years (these include archaeological objects from excavations or finds, but also things like statues and icons), regardless of their value.

Category C: Other cultural goods older than 200 years, and with a value of 18,000 euros or more.

This last category is more for high-end galleries; I suppose the goods in Category B are most relevant for most collectors and sellers of beads. Note that Category B includes all archaeological objects, regardless of value: that 10 USD ancient bead you have purchased on Ebay, now needs a whole lot more before it may be imported into the EU.

So where is Category A…? Those are cultural goods that have been obtained illegally, and cannot be imported at all.

Licence and documentation requirements for importing cultural jewellery

Customs authorities in the EU will require documentation for cultural goods entering the EU from outside. Depending on the object’s category, age, and origin, importers will need to provide either:

1. An Import Licence, or
2. An Import Statement

Import Licence (for Category B goods) If you’re importing archaeological items, such as beads or artefacts that were excavated or likely dug up, you will need an import licence. To get this, you must prove:

• The goods were legally exported from the country of origin.
• Or, if they were exported long ago, that they were legally in the seller’s possession before the regulation came into effect.

This licence is issued by the EU country where the goods will enter. Without it, the items can be held or sent back at customs.

Import Statement (for some Category C goods) For other items, such as ethnographic jewellery older than 200 years but not archaeological, you may be able to submit a simpler ‘import statement’ confirming lawful export and supporting documents (like a bill of sale, a certificate of origin, or a collection record). That’s everything from before 1825 at this point.

There are two exceptions:

• The country where the objects were created can not reliably be determined;
• The objects legally exported from their country of origin before April 24, 1972.

Both you’ll still need to prove, and it does not end there: in these two cases, you will also need to prove it was lawfully exported from the last country it has been in for a period longer than 5 years.

So that 10 USD ancient bead….let’s assume it is unclear where it was actually made in Antiquity. In that case, the seller will need to prove they obtained the bead themselves legally from the last country it has been in for 5 years. That means keeping close track of your inventory records.

I’m in the EU and want to buy old jewellery: what does the cultural goods-regulation mean?

If you are buying old beads or jewellery from outside the EU, say, from a seller in the Middle East, North Africa, or elsewhere – here are 4 pointers:

• Ask about the item’s origin and age. Beads described as “ancient,” “excavated,” or “dug-up” may fall into Category B, and you’ll need an import licence.
• Check documentation. Ask the seller to provide evidence of lawful export, such as a government-issued export permit or a dated invoice showing it was acquired before the regulation takes effect.
• Expect delays at customs. If the documentation isn’t complete, the item could be held, inspected, or refused entry. Factor this into your timeline and budget.
• Use reputable couriers and declare goods clearly. Mislabelled or undeclared cultural items can lead to seizures or penalties.

I’m outside the EU and want to sell jewellery: what does the cultural goods-regulation mean?

If you’re a seller based outside the EU and you sell older beads or jewellery to EU buyers, your business got significantly more difficult. Here are 4 pointers that might help:

• Assess your stock. Beads that were excavated, or come from archaeological or burial sites, are now considered sensitive cultural goods. Selling them into the EU requires supporting documentation.
• Provide export documentation. If your country issues cultural export permits, include a copy. If the item was acquired long ago, include invoices, collection records, or customs documents from that time.
• Be clear in your listings. If your item is over 250 years old, say so. If it’s not, and you’re confident it’s modern or a reproduction, state that clearly to avoid confusion or unnecessary red tape.
• Prepare for extra steps. Your EU buyers may ask you for additional documentation, especially for archaeological items. Having it ready builds trust and smooths the process.

Ethnic jewellery may get tangled up in procedures

A point to be aware of here is that regular ethnic jewellery may get tangled up in customs’ procedures.

Many customs’ officials do not recognise the difference between ethnographic and ancient pieces, because it requires a trained eye. That is not their fault: it’s a specific expertise. I am contacted on a regular basis by customs’ consultants both in my own country and in the U.S. to assist in identifying jewellery, because I am both an archaeologist and a jewellery historian. For transparency’s sake: that’s a ‘blind’ consultancy – I only get shown the objects themselves, but nothing on the seller or buyer.

In the experience I have with these identifications, I have found that most of it is actually ethnographic, not ancient: trade beads, vintage glass bangles, vintage rings…

And so while this technically has no consequence for the import and export of vintage traditional jewellery into the EU (compliance with UNESCO 1970 or CITES is another matter!), it does cause delays. That is just my personal observation, but one I wanted to share with you anyway. As I expect that ‘old-looking’ items may be subject to increased scrutiny, I would advise to be as accurate and complete as possible in the descriptions and documentation with each piece you wish to import into the EU.

The importance of provenance

When you have been following this blog for a while, you probably guessed that this section was coming…provenance! Provenance is now more important than ever. Honestly. There is no way around it anymore.

While not all older beads come with perfect paperwork, I would advise buyers and sellers to do what they can to build a clear record:

• Note when and where the item was acquired.
• Keep dated invoices, customs declarations, and permits.
• Avoid vague terms like “ancient style” if the item is in fact ancient.

It all boils down to keeping accurate track of your collection or inventory. And as time progresses, I suspect that this need for provenance will only continue to increase in the foreseeable future. Because while this particular regulation mainly affects archaeological items and cultural goods older than 250 years, it’s a matter of time before ethnographic jewellery starts to attract similar attention of lawmakers.

This blog on provenance is a good start!

EU-regulation on cultural goods: main takeaway for collectors of ethnic jewellery

Regulation (EU) 2019/880 isn’t about restricting trade for its own sake – although it definitely has serious effects for sellers and buyers alike. It’s about protecting cultural heritage and ensuring that items move across borders legally and ethically.

The main takeaway is that solid provenance is essential – to prove that an item you’re buying or selling has been excavated legally, or to prove it is not archaeological at all, or to prove it is younger than 250 years. The more complete and reliable your documentation is, the less hassle you’ll have at customs.

If you’re unsure about whether a specific item falls under the regulation, contact an import/export advisor or your national customs office. Better to check now than face difficulties later!

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References

See more on EU 2019/880 here:

https://www.europeanheritagehub.eu/document/regulation-eu-2019-880-of-the-european-parliament-and-of-the-council-of-17-april-2019-on-the-introduction-and-the-import-of-cultural-goods/

https://global.lockton.com/eu/en/news-insights/new-eu-regulation-on-cultural-goods-risk-implications-and-guidance

https://www.fieldfisher.com/en/insights/eu-regulation-2019-880-on-the-importation-of-cultural-goods-the-eu-commission-q-a

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