Summary on ILAB's engagement with the European Commission Art Market Expert Group in 2023/2024

In September 2023, ILAB was admitted to the working group "Dialogue with the art market", a sub-group of the European Commission's Expert Group on Cultural Heritage in Brussels (More information HERE).

ILAB represents over 1600 rare booksellers worldwide of which 780 individual firms are based on EU/EEA territory.

Over the last year, ILAB has participated in three meetings in Brussels, two at the premises of the European Commission (December 2023 and May 2024) and one conference, the "High Profile Art Market Event", organised by the European Commission during the BRAFA Art Fair in January 2024.

The "Dialogue with the Art Market Expert Group" was set up by the European Commission after many years of lobbying by the arts trade for EU officials to engage with art market participants before and during the development of cultural policy.
Representatives of the arts and culture sector, including governments, institutions and art market participants, were invited to apply for the group. ILAB was accepted and now represents the needs of the international rare book trade directly in Brussels.

For ILAB, joining this group was an important step to ensure that the rare book trade's perspective is represented in these high-level discussions. Rare booksellers face a rapidly evolving regulatory environment, with new rules often introduced without sufficient consultation or consideration of their practical impact on the trade.

One of the most pressing challenges for the rare book trade are increasingly stringent regulatory requirements, such as those related to the Anti-Money Laundering (AML) Directive, the Cultural Goods Import Regulation (EU 2019/880), and various customs and provenance requirements. These regulations are often burdensome for dealers already operating in a market that is far from homogeneous. Many booksellers find it difficult to comply with the documentation requirements of some regulations.

The trade representatives in the Group strongly oppose the image of the arts trade as a "hotbed of crime". In ILAB's case, rare booksellers are often at the forefront of cultural preservation and scholarship, ensuring that books - especially rare and fragile volumes - are properly cared for, preserved and made accessible to future generations.

The rare book trade is deeply concerned that regulation, while well-intentioned, may end up targeting the wrong areas or imposing one-size-fits-all rules that do not take into account the unique characteristics of the sector. The involvement of the trade ensures that regulators are made aware of these challenges and that new policies take into account the realities of the market.

Participation in these discussions is an essential step in combating the misrepresentation of the rare book trade. The involvement of ILAB allows the rare book trade to clarify the role of antiquarian booksellers as custodians of cultural heritage. By engaging directly with policy makers, ILAB is able to present a clear and accurate picture of its ethical standards and commitment to the preservation of cultural heritage.
The trade must have a seat at the table to advocate for proportionate and practical regulation. The rare book trade is largely made up of small "micro-businesses" that do not have the resources to comply with complex requirements. Without direct input from those working in the trade, regulations could become even more burdensome and disconnected from the realities of day-to-day business.

Over the course of the year, ILAB has submitted various written reports to the European Commission on the impact of the forthcoming Cultural Goods Import Regulation (EU Regulation 2019/880), which will come into full effect in June 2025, as well as AML requirements and their impact on the rare book trade.

In conclusion, to ensure that EU policymakers understand the unique characteristics of the rare book trade and avoid inappropriate decisions, the International League of Antiquarian Booksellers will continue to actively participate in the meetings in Brussels, advocating for balanced regulations in the face of new requirements, such as anti-money laundering and cultural goods import rules, which threaten booksellers already burdened by complex administrative obligations.

The ILAB Secretariat can be contacted for further details.

The next meeting of the Art Market Expert Group will take place at the European Commission in February 2025.

Text and images: Angelika Elstner