CPAC to Consider New MOU's with Jordan and Chile

On April 1, 2019, the U.S. Cultural Property Advisory Committee will consider proposed MOU's and associated import restrictions with the Kingdom of  Jordan and the Republic of Chile.Please consider commenting before the March 25, 2019 close.  

More about the CPAC meeting, including a public summary of the Jordanian request, can be found here.

To comment, click on the blue "Comment Now" button here.  If that does not work, paste this address into your web browser and try: https://www.regulations.gov/document?D=DOS-2019-0004-0001

The State Department Cultural Heritage Center's updated website provides much better information than in the past about what CPAC considers before recommending import restrictions.  This information may be accessed here.

To the extent possible, members of the public should try to comment on these factors.  Collectors and members of the trade should particularly be well placed to discuss how import restrictions negatively impact the study and appreciation of the history and culture of Jordan and Chile, and the people to people contacts collecting fosters.

The prospect of import restrictions on ancient Jordanian and Colonial and Republican era coins from Chile also raise specific factors that should be addressed.

Ancient Jordan was part of much larger Empires.  Greek, Roman, Byzantine and Islamic coins minted elsewhere also circulated in Jordan, but we cannot assume all such coins-- or even a substantial percentage of them-- were found there.

Even more "local issues" circulated regionally outside of Jordan.  For example, the coins of the Nabatean Kings would have circulated  throughout their kingdom, which included parts of modern day Jordan, Syria, Saudi Arabia, Egypt, Palestine and Israel.  Moreover, later Greek Imperial coins of the Decapolis also likely circulated throughout the area, which included Israel and Syria.

There is a threshold issue of whether Chilean coins meet the definition of "archaeological" or "ethnological" objects that are a predicate for them to be restricted. Coins struck in the 17th century and later are likely never to have been buried in the ground.  Moreover, as products of what were then considered modern industrial processes, one would be hard pressed to consider them "ethnological objects."

It is also difficult to assume coin types that circulated within Chile were found there.  Chile also was part of a much larger Spanish Empire that issued similar coins from multiple mints intended not only for use throughout that Empire but as trade coins.  These trade coins were also used extensively in the United States (where they were legal tender until 1857) and Asia, particularly China.  Even after Chile broke away from Spain, it struck similar trade coins that again ciruclated as far away as Asia and the United States.  So once again, it is impossible to assume that such coins were found in Chile.

Update 3/14/19:  The State Department has released a public summary of Chile's request.  It is focused on Pre-Columbian archaeological objects. One issue that should be noted is whether import restrictions may be placed on fossils because Chilean law includes paleontological material as a subset of archaeological material. The Chilean Public Summary can be found here.