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.
Wednesday, March 13, 2019
CPAC to Consider New MOU's with Jordan and Chile
Posted by Cultural Property Observer at 2:24 PM
Labels: Chile, coins, Collectors, CPAC, Import Restrictions, Jordan
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Daryl Rhoades, U.S.A. Ohio
Collector of Roman Imperial, Roman Provincial, Byzantine, Greek, Judaean, Nabataean, etc.
I have a handful of Nabataean, Judaean and many other types found in that region. I really like collecting these coins and have many in my online photo galleries. I like having detailed descriptions so I had to do a lot of research to learn how to read and display the scripts found on coins. Still a work in progress.
This is how I study and contribute to the community as many others do with websites.
I am somewhat familiar with UNESCO cultural property law and I have a copy of the Handbook of Cultural Property that I use as a guide, as to what countries I can shop from. The information is very outdated, pre 1986.
As it says for Jordan, All movable and immovable objects subject to export control and pre 1700 are antiquities and subject to the control of the department of antiquities and approval by the minister.
I believe it means you need a license and approval to export any antiquity before 1700 AD. If you cannot get approval then it will be illegal to export out of Jordan and subject to a penalty of a fine and possible imprisonment for up to two years.
I'm not sure what the point is for this new law because antiquities that are illegal are already filtered at customs points at USPS and other facilities. I've heard of collectors and dealers losing coins but not too often. I do not buy from Jordan because I don't want to lose the coins that I ordered and any other problem. Lots of educated collectors and dealers know where to buy from.
I do understand protecting cultural property, but I think this MOU is overkill, with all due respect. Because ancient coins are found all over and outside of any registered historic site. These laws restrict common items which I think is unreasonable. Some countries have itemization lists which is selective but doesn't restrict all artifacts and coins. I find this to be a much more reasonable approach.
A lot of collectors get angry about it because we ancient coin collectors are not criminals and don't want to share a cell with other convicts or get our coins confiscated.
I have an interest in coins of the Decapolis and other localities near Jordan. I can well understand a nation wanting to protect it's heritage but these coins are found in large numbers and have already been in the marketplace in many instances for hundreds of years. The coins come from many places, rarely Jordan itself any longer. Maybe the United States should be encouraging countries to have laws that encourage their own citizens to turn in finds, much like the Treasure Trove laws that work so very well in Britain. The collecting of ancient coins has been going on for a very long time, numismatic contributions to the understanding of ancient peoples and their cultures are well known and recognized. Coins are not some historical treasure or masterpiece that are irreplaceable to a regions history, they were manufactured in the thousands, sometimes in the millions, and it makes no sense to bag them all in a dark warehouse someplace and leave them to rot, or even worse leave them to deteriorate in the ground until they are nothing more than corroded disks. Let's engage with these nations to protect what is truly important to their heritage and work with them to create partners in a market that benefits everyone rather than just blindly ban everything from a region and condemn collectors and numismatists, many of whom are museums and other institutions meant to help people learn and enjoy history, to giving up on our love of collecting these small and usually common items of the ancient world.
Ancient coins were produced in the millions. The control and management of these coins will only hurt the study and presentation of ancient coins.
There are multiple examples where ancient coin collectors preserved the coins better than most museums and governments.
Furthermore, the study of ancient coins enhances the insight and understanding of differs cultures and peoples. Everybody is benefited by the collecting of ancient coins: history is better understood, coins are better preserved, different cultures are better appreciated, and collectors enjoy their collections.
These coins can be found in other countries. The Nabataeans had major cities in Israel including the famous city of Avdat.
Coins of the Decapolis coins can be found all over other countries as well. Archaeological reports in Israel and elsewhere confirms this.
The history of the Nabataens and the cities of the Decapolis do not only belong to the nation of Jordan. Additionally, their history belongs to other countries and not just where modern borders aline.
There is no purpose in passing this law. Thank you for your consideration.
Jared Clark USA Collector & Grad Student
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