Urgent alert: New EU import legislative will have detrimental impact on the rare book trade

Dear Colleagues,

A proposal for a European regulation of 13 July 2017 aims to combat the illegal import of cultural goods (including books over 250 years old) into the EU.

This text considers subjecting dealers to administrative obligations that are disproportionate with the pursued objective, which is the fight against the financing of terrorism.

The European legislation on the export of cultural goods has a value threshold for books of 50,000 euros (except incunabula and manuscripts). However, this proposal for import does not provide one; any book over 250 years old bought outside the EU is potentially concerned. Many books of the 17th or 18th centuries have no value and cannot be the subject of speculation for the purpose of financing any terrorist activity.

The full EU press release can be viewed here.

This proposal must go before the European Parliament in the coming months. It is essential to act quickly!

ILAB draws attention to the fact that:

• The vast majority of the world's antiquarian book trade takes place between Western countries in democracies with existing legislation on the illegal export of cultural goods: the European Union (including the UK), Switzerland, the United States, Australia, Russia, etc.
• The vast majority of the world's antiquarian book trade concerns European languages (Latin, French, English, German, Italian, Swedish, etc.), including books sold in Japan and China.
• The books or manuscripts that were looted or ransacked in Iraq and Syria were of a religious nature, in Semitic languages (i.e., Arabic or Aramaic), and were written or printed in their respective countries, not in the West.

Given the broad definition of “cultural goods” used in this proposal, the year from which manuscripts or books could not freely circulate would be those prior to 1768, and without any threshold of value. The criterion of "special interest" applicable to books is subjective, not to say arbitrary, and detrimental to the interests of traders. Besides, the definition chosen of “cultural goods” is inconsistent with the one found in Council Regulation (EC) No 116/2009 on the export of cultural goods which includes a threshold of value.

The European Union, which was built on freedom of movement, must first and foremost protect such values against arbitrary barriers to free trade.

Not only will the proposed legislation hinder business for the rare book trade, it will also add enormous burden on the EU administration who will receive and process disproportionate volumes of import statements.

That is why the International League of Antiquarian Booksellers have prepared a letter which can be used to contact authorities and/or local MEP's.
Please contact ILAB, if you wish to receive the letter: editor@ilab.org

All of ILAB's national member associations have received this letter and will act upon it. Individual booksellers can also make an impact by sending the letter to as many VIP’s among customers, to the members of Parliament and persons of influence from the cultural world.

To all booksellers: Even if you are not within the EU, your business will also be impacted should this proposal go through!

The rapporteurs of the draft regulation should be privileged as targets:

- Daniel Dalton (UK) http://www.europarl.europa.eu/meps/en/35135.html

- Alessia Maria MOSCA (IT) http://www.europarl.europa.eu/meps/en/124868.html

- Santiago FISAS AYXELÀ (ES) http://www.europarl.europa.eu/meps/en/96729/SANTIAGO_FISAS+AYXELA_home.html

- Kostas CHRYSOGONOS (GR) http://www.europarl.europa.eu/meps/en/125061/KOSTAS_CHRYSOGONOS_home.html

The ILAB Committee and the National Associations are counting on your help!

Best wishes

Sally Burdon
President, ILAB