Full Breakdown
Impact of EU Regulation 2019/880 on the Art Market Ahead of Tefaf
3/2/2026, 8:49:57 PM
Overview of the Regulation
The European Union's Regulation 2019/880, aimed at curbing the trade of stolen or looted cultural property, has significantly affected art dealers in the lead-up to the Tefaf art fair in Maastricht. This regulation mandates that items over 200 years old from non-EU countries must have proof of their legitimate export before entering the EU. Stricter requirements apply to archaeological items over 250 years old, and the law affects items valued above €18,000.
Challenges Faced by Art Dealers
Exhibitors at Tefaf have reported increased workloads and complications due to the new legislation. Will Korner, Tefaf’s head of fairs, noted that dealers have been in constant discussions with EU authorities to understand the practical implications of the regulation. Mark Dodgson, Secretary General of the British Antique Dealers’ Association (BADA), criticized the legislation as disproportionate, stating that it was based on a few anecdotal cases and does not effectively target the intended issues.
Sara Öberg Strådal, managing director of Dr Jörn Günther Rare Books, expressed frustration over the documentation required for items like a Sarum Missal, which left the UK legally two decades ago but lacks the necessary export proof due to changes in licensing requirements. The burdensome process has led some galleries to reconsider their participation in Tefaf, as the logistics of complying with the new rules add significant costs.
Perspectives on the Regulation
While many dealers oppose the regulation, some see potential benefits. Salomon Aaron, director at David Aaron gallery, acknowledged that although the regulation complicates transactions, it also enhances buyer confidence in the provenance of items. He noted that the regulation could create a market for items with well-documented histories, such as the Egyptian pieces his gallery plans to showcase at Tefaf.
However, Dodgson reported a decline in art market export numbers from the UK to the EU, with a 25% drop in the antiques and collector pieces segment since the regulation's implementation. This decline raises concerns about the long-term impact on the market, particularly for items with less clear provenance.
Official Responses and Future Implications
A spokesperson for the European Commission confirmed that there are no plans to revise the requirement for EU-based addresses for importers, emphasizing the need for jurisdiction in enforcing the regulation. The Commission's stance indicates a commitment to the regulation's goals, despite the challenges faced by dealers.
As Tefaf approaches, the art market will undergo a significant test of the regulation's impact. While it currently affects a relatively small segment of the market, the long-term consequences remain uncertain. The upcoming fair will likely provide further insights into how the regulation shapes the dynamics of art trade between the UK and the EU.
Verbatim Quotes
- “‘A small number of anecdotal cases seem to have been the basis for this legislation.” — Mark Dodgson, Secretary General, BADA
- “It would be very good if there could be exceptions for certain types of material, or certain countries, based on their [previous] export legislation,” — Sara Öberg Strådal, Managing Director, Dr Jörn Günther Rare Books
- “Yes, it makes everything slower and harder, but it does also create an opportunity,” — Salomon Aaron, Director, David Aaron Gallery
- “The regulation hits a relatively small proportion of the art market and it is still early days.” — Industry Analyst
