The State Department has announced a Cultural Property Advisory Committee (CPAC) Meeting to consider a new Cultural Property Agreement (CPA) with Romania and renewals of current CPAs with Albania and Nigeria.
CPAC will hold a session open to the public on July 14, 2026,
at 2:00 PM.
The State Department’s announcement can be found
here: https://www.state.gov/cultural-property-advisory-committee-meeting-July-14-16-2026/
The formal Federal Register notice can be
found here: https://www.federalregister.gov/documents/2026/06/04/2026-11197/notice-of-meeting-of-the-cultural-property-advisory-committee-proposals-to-extend-bilateral-cultural
The State Department is also soliciting written comments on the Regulations.gov website: https://www.regulations.gov/document/DOS-2026-0628-0001. If the link does not work, go to www.regulations.gov and search for docket number: DOS-2026-0628. Written comments and requests to testify are due on or before July 5, 2026, the day after our country’s 250th anniversary celebrations.
Issues for Coin Collectors
The big issues for coin collectors are grossly overbroad
designated lists. Past import restrictions on "Albanian
coins" demonstrate the scope of the problem. Recent import
restrictions have taken a maximalist approach that "designates"
virtually all coin types that may have circulated within a given country down
to the mid-18th Century, including many coin types that circulated regionally
or internationally in bulk. Once "designated," under current
procedures US Customs and Border Protection (CPB) can "assume" such
coins were illicitly exported from that country, even where they were
legitimately bought, sold and legally exported from our major trading partners
in the European Union (EU).
The issue is even more egregious for EU countries like
Romania and prospective EU members like Albania. EU law binding on EU
countries recognizes the rights of EU countries to export cultural goods. Yet,
CPB will detain, seize and repatriate coins and other artifacts to EU countries
with CPAs with the US, including Bulgaria, Cyprus, Greece and Italy, even where
they are legally exported from other EU countries like Germany with or without
an export permit as permitted under local law. It is as if the State
Department and CBP do not believe the EU exists!
The other big issue relates to
enforcement. Unfortunately, in the only case that addressed the
issue, courts in the US Fourth Circuit gave Customs a “green light” to detain,
seize and repatriate coins for no other reason that they were of types on a
“designated list” for import restrictions. This puts collectors
importing such coins at risk because it is often difficult, if not impossible,
to produce the documentation necessary for legal import under current “safe
harbor” procedures.
Issues for Dispossessed Minority Communities
Another major issue is CPAs being used to gain US government
recognition of foreign government rights to the cultural heritage of displaced
minority populations, most recently for Turkey.
Here, it is likely Romania will use this CPA to gain US approval for its
control over the cultural heritage of its displaced Hungarian population from
Transylvania. Moreover, a renewal of the CPA with Nigeria raises
similar issues for Biafrans and other minority groups within that
country.
Despite the ever-increasing number of overlapping import
restrictions on coins, it is still important to comment, for no other reason that
without public comment State Department bureaucrats could claim to political
appointees that restrictions on coins are “not controversial.” What should you say? It is better to write in
your own words about how import restrictions hurt your ability to access coins
and learn more about other cultures or even to get in touch with your own
cultural heritage. However, here is a model for coin collectors to
consider:
Please do not place new or renew import restrictions on
collector’s coins that prioritize “soft power” over the due process and private
property rights of American coin collectors. If you nonetheless enter
into a new CPA with Romania and renew the prior agreement with Albania, please
ensure that any designated lists are rewritten so that it is absolutely clear
that they do not impact coins that widely circulated or those legitimately
imported from legal markets abroad, particularly those in Europe. Also,
please do not put new restrictions on coins from Nigeria. Nigeria only used coins in recent times so
that such coins cannot be considered either archaeological or ethnological
objects under the governing legislation.
Coin collecting is a hobby that promotes cultural understanding and
relationships with collectors abroad. It is troubling that the State
Department Bureau of Cultural Affairs is behind efforts that do considerable
damage to a hobby that actually promotes the cultural understanding the Bureau aims
to foster.
