Art, collectibles and antiques sold online

• Regulation (EU) 2019/880 — introduction and import of cultural goods
• Regulation (EU) 2023/988 — GPSR with its antiques exclusion
• Directive (EU) 2015/849 — anti-money laundering for art market participants
• Regulation (EC) No 116/2009 — export of cultural goods

Who has to appoint one

Dealers and platforms selling art, collectibles and antiques into the EU. GPSR excludes antiques and products expressly requiring repair, but reproductions, prints, framed works and decorative pieces made today are ordinary consumer products with the usual obligations.

Thresholds and exemptions

Under the AML rules, art market participants dealing in transactions of €10,000 or more, including linked transactions, are obliged entities with customer due diligence duties. Cultural goods import licensing thresholds depend on the category and age of the object.

What must appear on the label

For new works and reproductions: manufacturer and responsible person details, product identifier and any safety warnings, for example for framed glass or wall fixings. For cultural goods: the import licence or importer statement as required by category.

Marketplace fields

Online platforms selling art must handle both the GPSR fields for modern items and the cultural goods documentation for older ones. Payment providers apply their own AML scrutiny to high-value art transactions.

Documentation you must hold

For new items: technical documentation and risk analysis. For cultural goods: the import licence for categories requiring one, or the importer statement, with provenance documentation showing lawful export from the country of origin. For AML: customer due diligence records, source of funds checks and suspicious transaction reporting procedures.

Standards and testing

REACH screening for pigments, coatings and treated wood in new works. Glass and fixing safety for framed pieces. No testing applies to genuine antiques.

Language requirements

Safety information for new items in the language of each member state of sale. Cultural goods documentation in the language of the customs authority.

When it applies

Import licences must be obtained before the goods enter the Union, and the electronic system for cultural goods has been phased in with the licensing obligation applying from June 2025.

How long records are kept

AML records for at least five years after the transaction. Provenance and import documentation for as long as the object is held and afterwards, since provenance follows the object.

What happens if you do not comply

Seizure of the goods and criminal proceedings for illicit cultural property, which is treated as trafficking rather than as a customs error. AML failures bring supervisory penalties. GPSR failures for modern items bring the usual withdrawal and fines.

Who enforces it

Customs authorities and national cultural heritage bodies, financial intelligence units for AML, and market surveillance for modern items.

Where the boundary lies

The antiques exclusion in GPSR is narrower than sellers assume: a vintage lamp rewired for use is not an antique in the relevant sense, it is a refurbished electrical product with the full electrical regime. And provenance documentation is now a border requirement rather than a market convention.

Questions we are asked

Does GPSR apply to antiques?

Products traded as antiques are outside GPSR, as are products expressly requiring repair before use. Reproductions and newly made decorative items are fully in scope.

What is needed to import an ancient object?

Depending on category and age, an import licence or an importer statement, supported by provenance evidence of lawful export from the source country.