HELP PREVENT IMPORT RESTRICTIONS ON GREEK COINS
giganews
restrictions on Greek cultural artifacts from the Neolithic period until the
mid-18th Century.The precise contents of the request remain secret, but the
State Department has published a "Public Summary" that suggests coins may be
included. The State Department is only allowing for a short public comment
period that ends on September 22, 2010. Comments made during the Italian
renewal process WILL NOT be reviewed for purposes of the Greek request.
To date, import restrictions have been put on Cypriot and Chinese coins.
Last May, almost two thousand collectors wrote the State Department to
express disapproval of any effort to extend import restrictions to Greek and
Roman coins from Italy. That decision remains pending. Now, however,
collectors must act quickly again to head off equally devastating import
restrictions on Greek coins struck as late as the 18th c. (This includes
Greek, Greek Imperial, Byzantine, Venetian, Crusader and Turkish issues.)
The effect could be significant. Restrictions allow US Customs to seize
coins on a "designated list" without regard to their place of discovery
unless they are accompanied by extensive documentation proving they were out
of the country for which restrictions were granted before the date the
restrictions were imposed. If restrictions are put in place on coins from
Italy and Greece, it will become much more difficult to import such coins
legally into the United States. Prices will rise and it may even become
financially impossible for dealers to import many of the common coins most
people collect.
You can read all about the Greek request at
http://exchanges.state.gov/heritage/whatsnew.html (note that Greece's formal
name "The Hellenic Republic" is used).
Comment procedures have also changed. You can no longer fax your comments.
Regular mail goes through security clearing and can take weeks to reach the
State Department. Instead, the State Department will accept comments online
through the website http://regulations.gov <http://regulations.gov/> .
Enter the docket number "DOS-2010-0339" into the "Enter Keyworld or ID"
field and click "Search." In the search results select the check box for
"Notices"-this will filter the results so that only the official notice is
showing. Finally, click on "submit a comment" under actions. Fill in the
box and submit it. After a day or so, your comments will then appear with
those of other collectors (as well as those in favor of restrictions).
It's always best to say what you feel in your own words, but these points
can certainly be made:
* The governing statute requires that restrictions only be applied on
artifacts "first discovered in Greece." But hoard evidence demonstrates that
Greek coins circulated extensively outside the confines of the modern Greek
nation state.
* The governing statute requires restrictions only be placed on
artifacts of "cultural significance." But coins -- which exist in many
multiples-- do not meet that particular statutory criteria, which is a "term
of art."
* The governing statute requires that less drastic remedies be tried
before import restrictions. But Greece has not tried systems akin the UK
Treasure Act and Portable Antiquities Scheme before seeking restrictions.
* The governing statute requires that restrictions be consistent with
the interests of the international community in cultural exchanges. But
restrictions will diminish the ability of American collectors to appreciate
Greek culture and could greatly limit people to people contacts with other
collectors in Europe.
* Restrictions are unfair and discriminatory to Americans. Collectors
in the EU--including Greece-- have no similar limitations on their ability
to import ancient coins.
What you say is important. But it's most important that you let the State
Department Cultural Property Advisory Committee know of your concern about
the potential impact of import restrictions on legitimate collecting.
I submitted the comments below at the Government website:
http://www.regulations.gov/search/Regs/home.html#submitComment?R=0900006480b
<http://www.regulations.gov/search/Regs/home.html#submitComment?R=0900006480
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There is a 2000 character limit (about 300 words), and I found it very
difficult to do justice to the subject within that limit.
Everyone submitting comments should edit what they intend to submit down to
300 words before visiting the Government website. I recommend that you have
your text ready in a word processor or notepad, so you can paste it in.
Thanks in advance for your comments on this important issue for collectors.
Dave Welsh
Classical Coins
www.classicalcoins.com
dwel...@cox.net
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Greece requests import restrictions, and after Cyprus and China, coins might
be included by any nation. Restrictions on coins contravene the intent and
letter of the CPIA:
* Restrictions may only be applied on artifacts "first discovered in" the
requesting state. Greek coins circulated widely outside modern Greece.
* Restrictions may only be placed on items of "cultural significance" --
coins have little.
* Less drastic remedies must be tried first. Greece has not tried
alternatives such as the UK Treasure Act and PAS.
* Restrictions must support interests of the international community in
cultural exchanges. The ability of American collectors to appreciate Greek
culture, and people to people contacts with collectors in Europe, would
decline.
* Restrictions on coins are unfair and discriminatory to Americans.
Collectors in the EU --including Greece-- face no such limitations.
Archaeological significance of coins can't compare to their importance to
the arts, numismatics, history, education and religion. Holding that
archaeology outweighs all these smacks of "archaeologie ueber alles."
Coins were not restricted prior to 2007, when the Cyprus MOA outraged
collectors. After saying coins were not "on the table," State accepted a
last minute request to include coins, then drew a veil of secrecy over the
whole affair. A FOIA suit became necessary to assess this reversal of the
policy of excluding coins from import restrictions.
In April 2009 the ACCG imported Chinese and Cypriot coins that were seized
and held for almost 10 months, requiring ACCG to act. The complaint is sub
judice, as is an appeal of the FOIA case. These initiatives receive an
entire section of a paper in the Miami Law series:
<http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1658519&download=yes>
http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1658519&download=yes
To impose import restrictions on coins while this challenge pends would be
injudicious. State should avoid this until legal review concludes.
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