This is a practical orientation for collectors, checked against the official texts cited below as they stood on 17 October 2026. It is not a legal opinion on a particular object. Age, value, materials and the destination country change the answer, and an export office or a customs broker can require documents this summary does not. Older pages on some local superintendency sites still quote the pre-2026 figures.
Buying an antique in Italy and taking it home is three permissions, not one. Italy controls the exit from Italian territory, including a shipment to another EU country. If the destination is outside the EU customs territory — the United States, the United Kingdom, Switzerland and most of the rest of the world — an EU export licence can be required as well. The country you ship to then applies its own customs duty, VAT and wildlife rules. A dealer’s invoice does not replace any of those steps.
Where you buy is a separate question. The Italy destinations guide is the orientation for Rome, Venice, Milan, Florence and the Florence biennale. Use the category guides before you pay: furniture, silver hallmarks, porcelain and ceramics, and Murano glass. A hallmark or a factory mark helps you describe the object on the form. It is not an export permit.
What cannot leave Italy at all
The Cultural Heritage and Landscape Code (decreto legislativo 22 January 2004, n. 42) forbids the definitive exit of cultural property already listed in article 10, paragraphs 1, 2 and 3. That includes things the Ministry has declared to be of cultural interest, and things that are cultural property by operation of law. Article 65, paragraph 1, is a ban, not a slow procedure. A refusal of a free-circulation certificate starts the declaration procedure under articles 14 and 68, paragraph 6, and until that procedure ends the object is under the protective rules of the Code.
Things belonging to the State, the regions and other public bodies, made by an artist who is no longer living and more than 70 years old, cannot leave until the verification in article 12 has been carried out (article 65, paragraph 2, letter a). Objects found by anyone, in any way, in the subsoil or on the seabed, and falling under article 10, belong to the State under article 91. Do not buy an archaeological object on the assumption that a receipt makes it exportable. Pandolfini’s conditions of sale say the same thing in one line: Italian archaeological finds cannot be exported.
The 70-year rule, €50,000, and the €13,500 line for books
For an ordinary work of art that is not already cultural property, the Code asks two questions: how old it is, and what it is worth. Law 17 March 2026, n. 40, in force on 14 April 2026, rewrote the value test in article 65. Article 5 of that law replaces the words “euro 13,500” with “euro 50,000” for the general category, and it keeps euro 13,500 only for books (beni librari). The Ministry’s export portal, SUE, has followed that split since 4 May 2026: one declaration for art objects under €50,000, and a separate declaration for books under €13,500.
Authorisation is required, under article 65, paragraph 3, letter a, as amended, for things of cultural interest, by an author who is no longer living, executed more than 70 years ago, when the value is above €50,000. The same paragraph’s new letter a-bis keeps the authorisation for books of that age and interest when the value is above €13,500. Below those lines, paragraph 4 says the exit is not subject to authorisation: under €50,000 for the general category, and under €13,500 for books. The statute says “above” and “below”. An object sitting on the exact figure is not spelled out, so put that case to the export office rather than guessing.
The €50,000 and €13,500 lines do not apply to the things in Annex A, letter B, number 1 of the Code. Those are archaeological objects, elements removed from artistic, historical or religious monuments, incunabula and manuscripts, and archives. They need authorisation whatever the value. The updated article 65, printed in the notes to Law 40/2026, says so in both the authorisation paragraph and the declaration paragraph.
Three further categories need authorisation under article 65, paragraph 3, letter c, because article 11 points them there. They are not saved by a low price:
- photographs, with their negatives and matrices, and cinematographic or audiovisual works, produced more than 25 years ago (article 11, paragraph 1, letter f);
- means of transport more than 75 years old (article 11, paragraph 1, letter g);
- goods and instruments of interest for the history of science and technology, more than 50 years old (article 11, paragraph 1, letter h).
Works by a living author, or whose execution does not go back more than 50 years, are not in the authorisation category. Article 11, paragraph 1, letter d, and article 65, paragraph 4, letter a, leave them to a declaration instead. On SUE that file is the contemporary-art self-certification (AAC), with a shorter form for works executed within the last 12 months. A recent piece of Murano glass often falls here. A nineteenth-century chandelier does not.
Between those poles, the export offices use a declaration they call D50: a work by an author who is no longer living, executed more than 50 years ago and less than 70. The Milan export office describes that file, and it describes the under-€50,000 declaration for works over 70 years. The procedural decree the offices cite is the Ministerial Decree of 17 May 2018, n. 246. The Code itself does not use the label “D50”; the portal does.
The self-declaration is still a filing
“Not subject to authorisation” does not mean you put the object in a suitcase. Article 65, paragraph 4-bis, puts the burden on the person concerned to prove to the competent export office, by a declaration under Presidential Decree 28 December 2000, n. 445, that the object really is in a category that does not need authorisation. The procedures are those set by ministerial decree. SUE calls the under-threshold form DVAL. You file it on the portal. The office can still call the object in.
If the office thinks the object may be one of the things of exceptional interest in article 10, paragraph 3, letter d-bis, it opens the declaration procedure of article 14. The Code says that procedure concludes within 60 days of the declaration. While it runs, do not ship.
The declaration is not a casual email. The Milan office warns that these are public acts and that a false statement is a criminal offence. Article 76 of Presidential Decree 445/2000 is the sanction for false declarations made under that decree. The value you declare has to be one you can support. Milan’s page lists the kinds of evidence the form accepts, and it says that if you do not have them you may ask for the commission to see the object.
Law 40/2026 added paragraph 4-ter: the declaration lasts as long as the free-circulation certificate. The certificate lasts five years (article 68, paragraph 5). Milan states that the DVAL and the D50 each last five years. SUE’s notice of 23 April 2026 says the DVAL form for art objects under €50,000 became available on 4 May 2026.
The attestato di libera circolazione
The certificate of free circulation (attestato di libera circolazione) is the authorisation for a definitive exit when article 65, paragraph 3, applies. Article 68 says the person who intends to take the object out makes a filing (denuncia) and presents the object to the competent export office, stating the market value of each thing. The filing can be withdrawn before the office notifies the certificate or the refusal.
The office has three days from presentation of the object to tell the relevant departments of the Ministry, and those departments have the next ten days to send anything they know (article 68, paragraph 2). The office then checks that the stated value is credible and, within 40 days of presentation of the object, communicates the certificate or a reasoned refusal (article 68, paragraph 3). The 40 days run from presentation of the object, not from the day you paid the dealer and not from the day a shipper collected it.
The certificate lasts five years. It is drawn up in three originals. One stays in the file, one is given to the applicant and must travel with the object, and one goes to the Ministry for the register (article 68, paragraph 5). Milan states that it is not renewable. A refusal starts the declaration of cultural interest. The object is then under article 14, and a sale contract that assumed the object could leave is your problem with the seller, not a reason the Ministry must let it go.
The offices that do this work are the Uffici Esportazione. Applications go through SUE, which the portal itself says is mandatory. From 4 May 2026 the portal split the channels: archival goods, books, and historical, artistic, archaeological and ethno-anthropological goods. You pick the type of object and then the competent office. Books and archives go to the export offices of the archival and bibliographic superintendencies. The Directorate-General for Libraries explains that transfer, made by a decree of 9 April 2025. Other objects go to the export office of the Archaeology, Fine Arts and Landscape superintendency for the relevant territory. Milan’s page is a clear public example of how one of those offices works: the commission sees objects presented for a certificate, a home visit can be asked for when the object is large, fragile or numerous, and the office states a revenue stamp of €16, payable on SUE.
The EU export licence, for shipments outside the EU
A shipment from Florence to Paris needs the Italian certificate or declaration. It does not need an EU export licence. A shipment from Florence to New York, London or Zurich can need both. Council Regulation (EC) No 116/2009 requires an export licence for cultural goods in its Annex I when they leave the customs territory of the Union. The United Kingdom and Switzerland are outside that territory. The licence is valid throughout the Union (article 2). The value test is made when the application is filed, and the value is the value in the Member State concerned.
Annex I covers a category only if the value reaches the threshold, except for the categories marked “whatever the value”. In summary, from the annex:
| Threshold | Categories |
|---|---|
| Whatever the value | Archaeological objects more than 100 years old; elements removed from monuments, more than 100 years old; incunabula and manuscripts; archives more than 50 years old |
| €15,000 | Mosaics and drawings; original engravings, prints and lithographs; photographs; printed maps more than 200 years old |
| €30,000 | Watercolours, gouaches and pastels executed entirely by hand |
| €50,000 | Original statuary and sculpture; books more than 100 years old; collections; means of transport more than 75 years old; other antiques in category 15, which includes furniture, clocks, musical instruments, glassware, carpets and goldsmiths’ work |
| €150,000 | Pictures and paintings executed entirely by hand |
Category 15 splits age as well as value. Between 50 and 100 years it lists specific goods, including articles of furniture and clocks. Over 100 years it covers other antique items not already in categories 1 to 14. Several of the art categories apply only when the object is more than 50 years old and does not belong to its originator. The annex is the list that counts.
The Italian test and the EU test are not the same test. A painting by a deceased artist, more than 70 years old, worth more than €50,000 but less than €150,000, needs an Italian certificate and does not meet the EU picture threshold. A piece of furniture more than 50 and less than 70 years old, worth more than €50,000, can need an EU licence while the Italian file is the D50 declaration rather than a certificate, because article 65’s authorisation for ordinary works starts at 70 years. Ask the office which combination your object and your destination actually require.
In Italy the licence is issued by the export offices. Article 74 of the Code, in the text published by the Cagliari superintendency, says they are the competent authorities, that the licence is issued together with the free-circulation certificate, and that it is valid for six months. The same office may issue it later, but not more than 30 months after the certificate. SUE lists the definitive EU licence (LED) as its own procedure. The Code’s article 73 still defines the old Council Regulation (EEC) No 3911/92 as “the EEC regulation”, and Annex A of the Code still prints older euro figures. Regulation 116/2009 replaced that regulation, and the export offices cite 116/2009. Use Annex I of 116/2009 for the EU thresholds, not the older figures in Annex A.
The form of the licence is still the one in Commission Implementing Regulation (EU) No 1081/2012. Article 9 says the period of validity shall not exceed 12 months from the date of issue. Italy’s six months, in article 74, sits inside that maximum. Commission Implementing Regulation (EU) 2026/1144 of 28 May 2026 will replace 1081/2012 with a central electronic licence system, and it repeats a maximum of 12 months for a standard licence. Article 15 of that regulation says it applies from 2 October 2031. It is not the system you file on today. Today you file on SUE.
Importing cultural goods into the EU
Regulation (EU) 2019/880 is the wrong document for shipping an Italian-made commode to America. Article 2, paragraph 2, says the regulation does not apply to cultural goods created or discovered in the customs territory of the Union. Recital 18 adds that Union goods which were exported and then return as returned goods do not need the import licence or the importer statement on the way back in.
The regulation matters when cultural goods created or discovered outside the Union enter the EU. Part B of the annex requires an import licence for archaeological objects, and for elements of monuments that have been dismembered, more than 250 years old, whatever the value. Part C requires an importer statement for other listed categories, including pictures, sculpture, books and manuscripts, when the object is more than 200 years old and the customs value is €18,000 or more per item. SUE’s notice of 30 July 2025 says the European ICG system for that import control is in operation, and the Commission’s questions and answers explain the licence and the statement. Milan tells importers to use the TRACES portal for that filing. If you are sending a Chinese vase or a non-EU archaeological object into Italy, this is the regime to read. If you are sending a Florentine commode out, it is not.
VAT and customs in the United States, the United Kingdom and Switzerland
Italian VAT and the destination’s import taxes are different charges. The Agenzia delle Entrate states that the ordinary Italian VAT rate is 22 per cent. Many dealers sell second-hand goods, works of art, antiques and collectors’ items under the margin scheme in decree-law 23 February 1995, n. 41: the tax is on the dealer’s margin, and a private buyer cannot recover it. From 1 July 2025, the Customs and Monopolies Agency records that decree-law 30 June 2025, n. 95, article 9, moved qualifying works of art, antiques and collectors’ items to the 5 per cent rate in the ordinary VAT regime. The notice says the 5 per cent rate does not apply when the margin scheme is used. In that notice, antiques for this purpose are goods other than works of art or collectors’ items, more than 100 years old, tariff code 9706.
Before you pay, ask which regime the invoice will use, and whether a sale that the seller exports outside the EU will be invoiced as an export. A private person who simply pays a margin-scheme invoice and arranges their own shipper should not expect a VAT refund. Ruling 497 of 11 October 2022 also records that the EU distance-selling rules used by the One Stop Shop do not apply to margin-scheme supplies. A business buyer shipping to another EU country should take that question to their own adviser rather than assume the Italian price is VAT-free.
United States
Heading 9706 of the Harmonized Tariff Schedule covers antiques of an age exceeding 100 years. In the 2026 Chapter 97 published by the US International Trade Commission, 9706.10.00 (an age exceeding 250 years) and 9706.90.00 (other antiques over 100 years) are free under the general rate. The chapter note says that if an article is entered for sale under 9706 and is later found not to be over 100 years of age, an additional duty is assessed. 19 CFR 10.53 allows a qualifying antique to be admitted free even if it has been repaired or renovated. If a substantial amount of material has been added, the original and the addition are appraised separately and duty is assessed on the addition. If the repair changes the article so that it loses its identity as the antique, the whole article is excluded from free entry under 9706.
An object under 100 years is not 9706. It is classified in its ordinary heading, where duty may be due. This page does not guess those rates. A customs broker classifies the entry. A free duty rate is not a waiver of other US requirements: Fish and Wildlife declarations, CITES permits, and the plant-health mark on wood packaging can all still apply. The importer has to be able to show the age. A verbal assurance from the shop is not that showing.
United Kingdom
The UK is outside the EU customs territory, so the Italian exit file and, where Annex I applies, the EU export licence come first. On arrival, HMRC’s guidance on the import-VAT value gives qualifying works of art, antiques and collectors’ items a reduced valuation. You take the value for duty, add the additional costs, and multiply by 25 per cent. Charging the 20 per cent VAT rate on that reduced value is what HMRC describes as an effective rate of 5 per cent. Antiques eligible for that treatment are products, other than works of art or collectors’ items, that are 100 years old or more, classified under heading 9706. Works of art and collectors’ pieces have their own headings in chapter 97 of the UK tariff. Look up the commodity code in that tariff for the duty rate on the day you import. This page does not copy a duty percentage out of a page that does not state one.
Switzerland and other destinations
Switzerland is also outside the EU customs territory. The Federal Tax Administration, on a page updated on 22 September 2026, states a normal VAT rate of 8.1 per cent. The reduced rate of 2.6 per cent on that page is for listed categories such as food, medicines and books, not for antiques. The Federal Office for Customs and Border Security says import tax is due on imported goods, including consignments of no commercial value, at the normal rate of 8.1 per cent unless the reduced rate applies. Check the Swiss tariff for the customs classification rather than assuming a zero duty.
Cultural property has a further Swiss rule. The Federal Office of Culture says it must be declared as such, and in detail, when it is imported, in transit, exported, or stored in a customs warehouse or bonded warehouse. Storage counts as an import under article 19 of the Cultural Property Transfer Act. A revision of the implementing ordinance, in force since 1 January 2026, added the date and the dimensions of the object to the declaration, together with the type and the place of manufacture or, for an archaeological object, the place of discovery.
For any other country, ask a broker who enters goods there. This page does not invent duty rates, VAT rates or de minimis amounts for destinations whose official tariff has not been cited above.
Ivory, tortoiseshell, rosewood and other restricted materials
A cultural-goods certificate is not a wildlife permit. If the object contains elephant ivory, marine-turtle shell, rosewood or another listed species, stop before you pay and get a written answer from the CITES authority in Italy and from the authority in the destination country. The export office of the Ministry of Culture does not issue CITES permits.
Ivory
Inside the EU, commercial trade in elephant ivory is heavily restricted. The Commission guidance published in the Official Journal on 30 December 2021, read with Commission Regulation (EU) 2021/2280, recommends that Member States stop issuing certificates for commercial trade in worked ivory unless the item is a musical instrument made before 1975 or an antique worked before 3 March 1947. For re-export — which is what a commercial shipment from Italy to the United States or the United Kingdom is — the guidance recommends that Member States not issue re-export certificates for commercial trade in worked specimens, except narrow cases such as pre-1975 musical instruments and pre-1947 antiques sold to a museum with the support of a cultural authority. “Worked”, in article 2(w) of Council Regulation (EC) No 338/97, means significantly altered from the raw state for jewellery, adornment, art, utility or a musical instrument before 3 March 1947, and no longer requiring carving to serve that purpose. A tusk, or a later inlay, does not become legal because the chest around it is old.
The United Kingdom adds the Ivory Act 2018. Dealing includes buying and selling, and it includes importing ivory into the UK to sell or hire. The ban covers elephant, hippopotamus, killer whale, narwhal and sperm whale. You register a standard exemption, or you apply for an exemption certificate, before you deal. The standard exemptions on the official page are: a musical instrument made before 1975 with less than 20 per cent ivory by volume; an item made before 3 March 1947 with less than 10 per cent ivory by volume, the ivory integral to it; a portrait miniature made before 1918 with a surface of no more than 320 square centimetres; and a sale or hire to a qualifying museum. An item made before 1918 can be put forward for an exemption certificate if it is of outstandingly high artistic, cultural or historic value. UK CITES permits are a separate filing. Registration under the Ivory Act does not grant them.
The US Fish and Wildlife Service states that commercial international trade in ivory is prohibited under CITES and further restricted by US law. An item qualifies for the Endangered Species Act antiques exemption only if the person claiming it can show all of the following: it is 100 years old or older; it is composed in whole or in part of an ESA-listed species; it has not been repaired or modified with any such species after 27 December 1973; and it is being, or was, imported through a designated antique port. The Service lists those ports, among them New York, Los Angeles, San Francisco, Miami, Chicago and Boston. Even then, CITES documents are still required, and wildlife must be declared to a USFWS Office of Law Enforcement. The Service’s page says the import of raw African elephant ivory is prohibited except for narrow cases such as a lawfully taken sport-hunted trophy. Read the current page before you bid on an ivory-inlaid commode, a miniature or a cane handle. Age alone is not permission to ship.
Tortoiseshell
The shell sold as tortoiseshell is marine turtle, typically hawksbill. Marine turtles are listed in CITES Appendix I. Commercial international trade in Appendix I species is not a routine antique exception. Fans, boxes, frames and inlays should be treated as unable to travel until the CITES authorities on both sides have said otherwise in writing.
Rosewood and other woods
Most Dalbergia species, the rosewoods, are in CITES Appendix II with annotation #15. Brazilian rosewood, Dalbergia nigra, is in Appendix I and is outside that annotation. The annotation, as published by the CITES Plants Committee, exempts finished products only up to 10 kg of the wood of the listed species per shipment, and it exempts finished musical instruments, their parts and their accessories. The Committee’s reading of the 10 kg limit is the weight of that species’ wood in each item, not the weight of the crate, and weights of different listed species are not added together. Other species, including Dalbergia cochinchinensis and the Mexican population, sit under different annotations. Conferences of the Parties amend annotations, so check the current Appendices and ask the management authority. A veneered commode can fail this test even when the Italian cultural-goods file is in order.
Switzerland’s import-permit guidance says Dalbergia wood products generally need a CITES certificate from the country of export and a Swiss import permit, and that permanent permits are not issued for Dalbergia nigra, Dalbergia cochinchinensis or the Mexican population. Other destinations can be stricter than the annotation. Coral, certain reptile skins and ivory in the same object raise the same kind of question. Ask while the object is still in the shop.
What dealers and auction houses actually do
The Code puts the filing on the person who intends to take the object out of Italy. Article 68, paragraph 1, is addressed to that person. Article 65, paragraph 4-bis, puts the burden of the declaration on “the interested party”. Neither article requires the seller to obtain the paper.
Auction houses commonly say so in the conditions of sale, and they commonly say that a refusal or a delay does not cancel the purchase or postpone payment. Pandolfini cites the Code and Regulation 116/2009, declines responsibility for whether the permits are issued, and says a refusal cannot justify cancelling the purchase or withholding payment. Il Ponte’s general conditions for 2025 put the same burden on the buyer, for Italy and for the destination country, including customs and protected species. They also say the house may, if the buyer asks and has already paid, file the certificate, the DVAL or the export licence. The fee stated in those general conditions is €150 plus VAT per work, plus any transport, unless the conditions of that particular sale set a different figure. The house does not guarantee the result.
Read the conditions of the sale you are bidding in, not a general memory of how auctions work. Ask whether a lot mark means a certificate already exists, and if it does, ask for the date, the value stated on it, and whether the five-year life has started to run. A certificate in the seller’s name has to be one you are allowed to use, and the original that article 68 says must travel with the object has to be the one that will actually be in the crate.
A dealer can agree to file, or to wait for the outcome, as a term of the contract. Get that term in writing before you pay: who files, who pays the stamp and the shipper, and what happens if the office refuses or opens a declaration procedure. A refusal can mean the object cannot leave and is now inside a cultural-interest procedure. That is the moment a friendly verbal promise is not enough.
Choosing a shipper, and packing and insurance
Use a shipper that moves fine art and cultural goods as a normal part of its work, and that will not collect the object until the Italian document this shipment needs is in hand: the certificate or the validated declaration, and the EU licence if the destination is outside the EU and Annex I applies. A general removals company can crate a table. It is a poor place to discover that the licence was never filed.
Ask, in writing, for a condition report and photographs before packing, for the crate specification, and for confirmation that any solid-wood packaging is treated and marked under ISPM 15, the plant-health standard for wood packaging in international trade. Give the shipper the invoice, the Italian document, the EU licence if there is one, dimensions, and a materials list that mentions ivory, shell, rosewood and any other restricted substance. The destination entry is usually prepared by the shipper’s broker, who cannot classify what you have not described.
Insure the transit for an agreed value, from the moment the shipper takes the object until delivery, and read the wording. Ask what is excluded, whether the shipper’s own liability is capped at a figure far below the purchase price, and who is the insured. This page does not quote a premium or a transit time. Those come from the quote for this object and this route. Split the quote into filing, any viewing by the office, release of the documents, collection, export clearance, freight, import clearance and delivery, so a delay in one stage is visible.
Timelines that are actually published
There is no official door-to-door figure for “shipping antiques from Italy”, and this page does not invent one. The times that are published are procedural.
- The export office must communicate the free-circulation decision within 40 days of presentation of the object (article 68, paragraph 3 of the Code).
- If a declaration of cultural interest is opened from a self-declaration, article 65, paragraph 4-bis, says that procedure concludes within 60 days of the declaration.
- The certificate lasts five years and must travel with the object. Milan states that it is not renewable.
- The Italian EU export licence issued with the certificate is valid for six months (article 74). Implementing Regulation 1081/2012 caps an export licence at 12 months from issue. A certificate you obtained two years ago does not keep an EU licence alive.
- The Milan export office states that a DVAL is taken in charge within three days and, unless the office calls the object in or opens checks, is returned by certified email within two weeks. That is one office’s published practice, not a national deadline. Other offices publish their own days and their own public hours.
Do not book a flight, a fair or a house delivery on the assumption that the 40 days, or Milan’s two weeks, will be the whole story. Presentation of the object is itself a step, and a refusal replaces the shipping calendar with the declaration procedure.
Buyer checklist
- Identify the object before you discuss export: materials, approximate date, dimensions, photographs of the front, back and any marks. The category guides above are the place to start.
- Ask whether it is already declared of cultural interest, and whether a certificate, a validated declaration, or an entry certificate (CAS or CAI) already exists, with the date and the value stated on it.
- Decide which Italian file the object needs: a ban, a certificate, a DVAL, a D50 or a contemporary-art declaration. Then ask whether Annex I of Regulation 116/2009 also requires an EU licence for your country.
- If there is ivory, tortoiseshell, rosewood or another listed material, get the CITES answer, and the destination country’s answer, before you pay.
- Agree in writing who files on SUE, who pays, and what happens if the office refuses or opens a declaration procedure. Read the auction conditions if you are bidding.
- Ask whether the invoice is margin-scheme or ordinary VAT, and whether the seller will treat an extra-EU shipment as an export.
- Choose the shipper before the crate is built. Give them the materials list. Do not let them collect the object until the Italian document, and the EU licence if it is required, is released.
- Keep the original that must accompany the object, and keep the destination customs entry. You will need both if the object is questioned later, or if you ever bring it back.
FAQ
Can I fly home with an antique and sort the paperwork out later?
No, if article 65 applies to it. Leaving Italy, including for another EU country, can require a certificate or a validated declaration first. The airline does not issue either one. The export office does, on SUE.
Is the threshold still €13,500?
For most art objects, no. Law 17 March 2026, n. 40, in force on 14 April 2026, replaced €13,500 with €50,000 in article 65. Books stay at €13,500. Archaeological objects, parts removed from monuments, incunabula, manuscripts and archives need authorisation whatever their value. Some older office web pages still show €13,500. The statute and the SUE portal are the current references.
Does the EU export licence replace the Italian certificate?
No. The certificate or the declaration is about leaving Italy. Regulation 116/2009 adds a licence when the object is in Annex I and is leaving the EU customs territory. A shipment to another EU country does not need that EU licence. A shipment to the United States, the United Kingdom or Switzerland can need both, and the two age and value tests are not identical.
Are antiques over 100 years old duty-free in the United States?
Heading 9706 covers antiques of an age exceeding 100 years, and the general rate for 9706.10.00 and 9706.90.00 in the 2026 Harmonized Tariff Schedule is free. Customs can deny that treatment if the age is not shown, if later repairs make the article lose its identity as the antique, or if the heading is wrong. Other border requirements, including wildlife rules, can still apply. Objects under 100 years are not entered under 9706.
Will the auction house obtain the export papers?
Only if the conditions of that sale say so. Pandolfini and Il Ponte both put the export risk on the buyer, and both say a refusal does not cancel the purchase or justify non-payment. Il Ponte’s 2025 general conditions say the house may file after the buyer has paid, at a stated fee of €150 plus VAT per work unless that sale’s conditions set another figure, and that the house does not guarantee the outcome.
Can I ship antique ivory, tortoiseshell or rosewood?
Do not assume so. EU guidance recommends that authorities refuse commercial re-export certificates for worked ivory except narrow cases, such as certain pre-1975 musical instruments and certain pre-1947 antiques sold to museums. The UK Ivory Act restricts dealing, including import for sale. US Fish and Wildlife rules add further conditions, including designated ports, and they still require CITES documents. Marine-turtle shell is CITES Appendix I. Rosewood is listed too, with a narrow finished-product annotation that does not cover every veneered piece. Ask both authorities before you pay.
How long does the certificate take?
The Code gives the export office 40 days from presentation of the object to communicate the decision. That is not a door-to-door shipping time. The object has to be presented, and a refusal starts a separate procedure. The Milan export office says a DVAL is normally returned by certified email within two weeks unless the goods are called in. Other offices publish their own times.
Does Regulation 2019/880 apply when I ship an Italian antique to America?
No. That regulation governs cultural goods entering the EU, and article 2 says it does not apply to goods created or discovered in the EU customs territory. It matters if you later import into the EU an object that was created or discovered outside the EU, above the age and value lines in its annex.
Related guides
- Antiques destinations in Italy — where a short buying trip actually starts.
- Italian antique furniture — the objects most often crated, and the ones where rosewood and later restoration matter.
- Italian silver hallmarks — how to read a mark before you describe the object on a form.
- Porcelain and ceramics — factory and town, which is also what an export description needs.
- Murano glass — including later pieces that may be a contemporary-art declaration rather than a certificate.
Official texts
The figures and the deadlines above are taken from these texts. If a later amendment moves a threshold, the text wins.
- Law 17 March 2026, n. 40 — raises the general article 65 threshold from €13,500 to €50,000, keeps €13,500 for books, and aligns the life of the declaration with the certificate. In force 14 April 2026. The notes print the amended articles 65 and 68.
- Code of Cultural Heritage, consolidated text hosted by the Cagliari superintendency (February 2024) — articles 11, 74 and 91, which Law 40/2026 did not rewrite. Use the 2026 law, not this PDF, for the €50,000 and €13,500 lines.
- SUE, the Ministry of Culture export portal — current form names, including DVAL 50,000 and DVAL 13,500.
- Export office, Milan superintendency — how a certificate, a DVAL and a D50 are filed, and the times that office publishes.
- Directorate-General for Libraries — export offices for archival and library goods.
- Regulation (EC) No 116/2009 — the EU export licence and Annex I.
- Implementing Regulation (EU) No 1081/2012 — licence validity not exceeding 12 months, until Regulation 2026/1144 applies.
- Implementing Regulation (EU) 2026/1144 — electronic EU export licences, applicable from 2 October 2031.
- Regulation (EU) 2019/880 — import of non-EU cultural goods into the Union.
- Agenzia delle Entrate — ordinary VAT at 22 per cent.
- Customs and Monopolies Agency notice — 5 per cent VAT on qualifying art, antiques and collectors’ items from 1 July 2025, not combined with the margin scheme.
- HTS Chapter 97 (2026) and 19 CFR 10.53 — US treatment of antiques over 100 years old.
- HMRC: how to value goods for import VAT — the UK reduced valuation for qualifying antiques.
- Swiss Federal Tax Administration — normal VAT at 8.1 per cent — and the Federal Office of Culture on declaring cultural property at the Swiss border.
- EU ivory guidance (OJ C 528, 30.12.2021), the UK Ivory Act guidance, the US Fish and Wildlife ivory FAQ, and the CITES Appendices.
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