Time Again to Tell the Cultural Property Advisory Committee What You Think About Import Restrictions on Coins for Cyprus, and any Effort to Place New Restrictions on Coins from Guatemala and Peru

 The State Department has announced a Cultural Property Advisory Committee (CPAC) Meeting to consider renewals of current cultural property agreements (CPAs) with Cyprus, Guatemala and Peru. 

CPAC will hold a session open to the public on October 27, 2026, at 2:00 PM. 

The State Department’s preliminary announcement can be found here:  https://www.state.gov/cultural-property-advisory-committee-meeting-october-27-29-2026.  The formal Federal Register notice can be found here:  https://www.federalregister.gov/documents/2026/09/24/2026-19533/meeting-of-the-cultural-property-advisory-committee-proposals-to-extend-bilateral-cultural-property   

 The State Department is also soliciting written comments here:  

https://www.regulations.gov/document/DOS-2026-1058-0001

If the link does not work, please go to regulations.gov and search for “Cultural Property Advisory Committee” or search for the docket number, DOS-2026-1058.

Comments are due on or before October 16, 2026.

The renewal for Cyprus should be controversial for several reasons.  First and foremost, the import restrictions on coins were initially imposed against the recommendations of CPAC in circumstances that raise serious conflict of interest issues.  See  https://accguild.org/news/13693260

Once again, there also is a serious issue that the State Department has ignored scholarly evidence provided about the circulation of “Cypriot coins” outside Cyprus, which, after all, is an Island nation that was at the center of ancient trade routes.  Even worse, after the last renewal, additional restrictions were added, this time on widely circulating types, including coins minted under Imperial authority elsewhere.  See https://culturalpropertyobserver.blogspot.com/2022/07/cypriot-designated-list-expanded.html

The issues related to the CPA with Cyprus are even more egregious given that nation’s voluntary association with the European Union.  While Cyprus is a Democracy, it has very stringent laws that limit collecting Cypriot coins.  However, the real annoyance is that the State Department and US Customs pretends that Cyprus is not part of the EU.  EU rules govern all exports from the Union.  They explicitly allow EU members to export cultural goods, with or without a permit, depending on value as determined by the member state.  Most EU members allow exports of collector’s coins, usually without a permit.  However, Customs will seize any coin on the designated list for Cyprus, or the other EU countries with CPAs (Bulgaria, Greece, and Italy) even where the coins were legally exported from a sister EU country.   Representatives of the trade and collectors have voiced this concern over and over again, most recently with the renewal of the CPA with Greece, but it has fallen on deaf ears.

The current CPAs with Guatemala and Peru focus on pre-Colombian artifacts and colonial era ethnological material, but there have been previous requests to impose import restrictions on Spanish colonial and early Republican coinage from Latin America, despite the fact such coins were also legal tender in the US until 1857.

As noted previously, for coin collectors, the big issue is the grossly overbroad designated lists that cover coins that circulated regionally or internationally.  

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.

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 get in touch with your own cultural heritage.  However, here is a model for you to consider:

Please do not renew current import restrictions that prioritize “soft power” over the rights of American coin collectors.  Import restrictions on Cypriot coins should be dropped because they were imposed, not based on facts, but on a possible serious conflict of interest.  See https://accguild.org/news/13693260   Furthermore, to the extent they are being considered, there should be no new restrictions on Spanish Colonial or Republican era coins of Guatemala and Peru.  These coins circulated very widely, including as legal tender in the United States.  If restrictions are nonetheless again extended to coins,  please ensure that the 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.  Coin collecting is a hobby that promotes cultural understanding and relationships with collectors abroad.  It should be encouraged, not discouraged by the State Department Bureau that focuses on fostering such relationships.