The US Cultural Property Advisory Committee is soliciting comments concerning the proposed renewal of import restrictions on cultural goods, including coins, down to the end of the Tang Dynasty. The time to comment is exceptionally short, ending on April 15, 2018.
This renewal should be of particular interest to collectors who specialize in Chinese coins.
Comments are to touch on the following four determinations: (1) that the cultural patrimony of the requesting nation is in jeopardy from the pillage of archaeological materials; (2) that the requesting nation has taken measures to protect its cultural patrimony; (3) that U.S. import restrictions, either alone or in concert with actions taken by other market nations, would be of substantial benefit in deterring the serious situation of pillage, and (4) import restrictions would promote the interchange of cultural property among nations for scientific, cultural, and educational purposes.
For Chinese coins, the key points relates to determinations 2-4: Why should the US Government place restrictions on American collectors given the huge internal market in ancient Chinese coins within China itself, particularly when China and other countries have not imposed similar restrictions on the ability of their own citizens to deal and trade in such coins? Under the circumstances, continued restrictions will only diminish the ability of Americans to learn about and appreciate Chinese culture from "hands-on" experience with Chinese coins without any impact on the huge trade in Chinese coins abroad. Other issues are that Chinese cash coins circulated widely outside China, including E. Africa, Japan, Indonesia, etc. and that it is difficult for all but experts to tell "restricted" Tang Dynasty and earlier cash coins from later "unrestricted" ones.
Finally, there is a question of reciprocity. U.S. collectors have had to deal with a veritable avalanche of fake U.S. collectors' coins produced in China. If China is going to do nothing about it, why should the U.S. "help China" secure its "cultural heritage?"
To comment on the renewal, use the regulations.gov portal here: https://www.regulations.gov/document?D=DOS_FRDOC_0001-4477 and click on the “comment now” button. Note you are commenting on the China MOU renewal as CPAC is also accepting comments regarding another proposed MOU with Ecuador.
The Department of State requests that any party soliciting or aggregating comments received from other persons for submission to the Department of State inform those persons that the Department of State will not edit their comments to remove any identifying or contact information, and that they therefore should not include any information in their comments that they do not want publicly disclosed.
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