Export/removal and import/introduction of cultural goods and objects that are not cultural goods

Cultural goods must not be taken out of the country without a special permit issued by the conservatory departments
 

The issues of export/removal and import/introduction of cultural goods of the Republic of Croatia are regulated in detail by the following: Act on Protection and Preservation of Cultural Property (OG 145/24), Ordinance on the Conditions for Granting Permits for the Export and Removal of Cultural Goods from the Republic of Croatia (OG 77/25), Council Regulation (EC) No. 116/2009 of 18 December 2008 on Export of Cultural Goods.

Regulation (EU) 2019/880 of the European Parliament and of the Council of 17 April 2019 on the introduction and on the import of cultural goods And the Commission Implementing Regulation (EU) 2021/1079 of 24 June 2021. laying down detailed rules for implementing certain provisions of Regulation (EU) 2019/880 of the European Parliament and of the Council on the introduction and the import of cultural goods.

Export/removal of cultural goods

In accordance with international and European regulations, the export/removal of national treasures is prohibited. Accordingly, the Act on the Protection and Preservation of Cultural Goods of the Republic of Croatia stipulates that cultural goods entered in the Register of Cultural Property of the Republic of Croatia constitute national treasures and that their permanent, indefinite export/removal from the Republic of Croatia is not permitted.

Exceptionally, Article 53 of the Act allows a cultural good to be temporarily exported/removed from the Republic of Croatia abroad for the purpose of exhibitions, expert evaluations, conservation and restoration or for other justified reasons.
 
In addition to the system regulating the export/removal of cultural goods, the conditions for the export/ removal of objects that do not have the status of cultural goods have also been set forth.
 
The regional conservation offices of the Ministry of Culture and Media are competent for issuance of export/removal licences, and the competent authority for the City of Zagreb is the City Institute for the Conservation of Cultural and Natural Heritage.
 
The forms for licences for export/removal of cultural goods, as well as the certificates for the export/removal of objects that do not have the status of cultural goods, may be obtained at the above-mentioned offices/services and at the Institute for the Conservation of Cultural and Natural Heritage.

The export of cultural goods from the Republic of Croatia implies the export to third countries outside the EU customs area and the removal of cultural goods from the Republic of Croatia implies the removal to the EU member countries.

Procedure for issuing a licence for the temporary export/removal cultural goods

The application for export/removal of cultural goods is submitted to the regional conservation office of the Ministry of Culture and Media in the area where a particular cultural good is located, i.e. to the City Institute for the Conservation of Cultural and Natural Heritage in the City of Zagreb for the Zagreb area. The application is submitted by completing the appropriate form, printed in both Croatian and English. The forms must be filled out either by typewriter or by hand in legible, capital letters, and must not contain any deletions, corrections or other alterations.
  
The following should be enclosed with the filled out form:
  • Documents showing all relevant data on the cultural property and its legal status (ownership and other) at the time of submitting the application, together with all other related documents (invoices, expert assessments etc.), when required;
  • A clearly and visibly certified photograph of the particular cultural good provided by the competent authority, or, when required and at the discretion of the competent authority, several photographs sized 8 x 12 cm. The photographs must show the cultural property in its entirety, in a recognisable manner;
  • Documents proving property insurance in the event of damage, destruction, or unlawful alienation of the good, in accordance with the Act on the Protection and Preservation of Cultural Goods.
  
Types of licences for export of cultural goods to third countries are as follows
  
1. Standard export licence
 
The standard licence is issued for every cultural good separately. If a shipment contains multiple cultural goods, the competent authority decides on issuing a single export licence or several export licences.
 
The validity period of a standard export licence is maximum one year.
 
2. Specific open export licence
 
The specific open licence may be issued for a specific cultural good that is temporarily, frequently or regularly exported from the Republic of Croatia for the purpose of use and/or exhibition. The specific open licence covers the repeated export of a cultural good by a specific person or organisation.
The cultural good must be in ownership or lawful possession by a natural or legal person or organisation that uses and/or exhibits that cultural good. The export licence may be issued only if the competent authority determines that the applicant has all necessary guarantees for the return of the cultural good to the Republic of Croatia in good condition, if the cultural good is described well or marked in such a way that, at the time of temporary export, there is no doubt that the cultural good being exported is actually the cultural good described in the special open licence.
The validity period of the specific open export licence is maximum one year, with the possibility of a 5-year extension.
 
3. General open export licence
 
The general open licence may be issued to museums or other institutions to cover the temporary export of any of the goods that belong to their permanent collection that are liable to be frequently or regularly exhibited in a third country. The general open licence covers the temporary export of any cultural good that is a part of the permanent collection of a museum or another institution.

The licence may be issued only if the competent authority determines that the applicant has all necessary guarantees for the return of the cultural good to the Republic of Croatia in a good condition.
The validity period of the open export licence is maximum one year, with the possibility of a 5-year extension.

The exporter is obliged to enclose the export licences with the customs declaration in case of temporary export of the cultural good.

Types of licences for the export of cultural goods to the EU member countries

  1. Standard export licence 
  2. Specific open export licence 
  3. General open export licence
With regard to their content, these licences are equal to the export licences, but the exporter is obliged to enclose them with the customs declaration in case of a temporary export.
 
In accordance with Article 1 of the Council Regulation (EC) no. 116/2009 the term cultural goods refers also to the following objects:

According to the age:
  • More than 50 years: paintings and canvases, aquarelles, gouaches and pastels, mosaics, original engravings, graphics, serigraphs and lithographs with their corresponding plates, and original posters, original sculptures or statues and copies made by the same method as the original, photographs, films and their negatives, archival materials, incunabula and manuscripts, including maps and musical scores, individually or in collections, musical instruments, glass, objects made of gold and silver, furniture, clocks, watches and their parts, wooden objects, pottery, tapestries, carpets, wallpapers, optical, photographic and cinematographic equipment, weapons, toys;
  • More than 75 years: means of transport;
  • More than 100 years: archaeological objects, elements that are part of artistic, historical, or religious monuments that are not in a single piece, books individually or in collections;
  • More than 200 years: printed maps. 
According to the monetary value: 
  • Any value: archaeological objects, monuments that are not in a single piece, incunabula and manuscripts, archival materials;
  • Above EUR 15,000 Mosaics and drawings, engravings, photographs, printed maps; 
  • Above EUR 30,000: aquarelles, gouaches, and pastel paintings;
  • Above EUR 50,000: sculptures, books, collections, means of transport, any other objects; 
  • Above EUR 150,000: paintings. 
Objects and collections of historical, ethnographic, numismatic, zoological, botanical, mineralogical, and palaeontological importance, as well as items from anatomical collections, are evaluated according to the criterion of high value and rarity, and a monetary value exceeding EUR 50,000.
In accordance with the criteria listed in Annex 1 of the Council Regulation (EC) no. 116/2009 the above-listed cultural goods required the export licence.

Refusal to issue a licence for the export/removal of cultural goods

The regional conservation offices, i.e. the City Institute for the Conservation of Cultural and Natural Heritage in the City of Zagreb may refuse issuing of the licence for the export/removal of cultural goods if the relevant cultural goods is of exceptional importance. If the issuance of an export licence is refused for a cultural good, a notice of this decision is sent to all competent authorities of the Ministry of Culture and Media, the Ministry of the Interior, and the Ministry of Finance - Customs Administration.

Export/removal of objects that do not have the status of cultural goods

For the export/removal of objects that are not registered in the Register of Cultural Property, the regional conservation offices, or the City Institute for the Protection of Cultural and Natural Monuments in the City of Zagreb, issue a certificate for export/removal using the form contained in Annex IV of the Ordinance.

Import and introduction of cultural goods

In order to prevent the introduction into the Union of cultural goods illicitly exported from third countries, pursuant to Regulation (EU) 2019/880, Commission Implementing Regulation (EU) 2021/1079, and in accordance with Article 56 of the Act on the Protection and Preservation of Cultural Goods (Official Gazette 145/24), cultural goods may be imported into the Republic of Croatia based on an import licence or an importer statement issued by the regional conservation offices of the Ministry of Culture and Media.

The Regulation does not apply to the cultural goods that were created or discovered in the EU customs area.
The import licence application is submitted via the ICG system (the centralised electronic system for managing the import of cultural goods from third countries into the EU customs territory), the use of which will be mandatory as of 28 June 2025.

The ICG System User Manual can be found at the following link/PDF.

Temporary admission for the purposes of education, science, or research

The temporary admission of cultural goods is permitted without an import licence or importer statement, i.e. it is not subject to obtaining an import licence or an importer statement in the following cases:
  • When the cultural goods are used exclusively within scientific or public educational institutions;
  • Temporary loans by museums or similar institutions;
  • Digitisation;
  • Restoration or conservation carried out within a public museum or a similar institution. 
Note: In order to benefit from an exemption, public organisations and institutions, as well as authorised private or semi-private organisations and institution must be registered in the ICG System.

Documentation required for import proving the licit provenance of cultural goods

The applicant must submit to the competent authority, via the system, the evidence that the relevant cultural good has been exported from the country of interest in accordance with its laws and regulations, or provide evidence that such laws and regulations are non-existent at the time the cultural goods were taken out from the territory of the country of interest. In particular:
  • The import licence application must include a signed statement by means of which the applicant explicitly assumes responsibility for the truthfulness of all statements provided in the application;
  • If, under the laws and regulations of the country of export, the cultural good is subject to a prior authorisation, the applicant is obliged to upload copies of the relevant export certificates or licences issued by the competent authority of the exporting country to the ICG system;
  • Colour photos of the particular object must be enclosed to the application, in accordance with the specifications set out in Annex II;
  • Other types of documents e.g. ownership certificate, condition reports, sales invoices, customs documentation proving previous movements of the cultural good, seller statements, expert appraisals, museum publications etc.

Processing of applications, the deadline for issuing a decision on the import/introduction of cultural goods

Once the applicant has submitted all the requested information, the competent authority, i.e. the regional conservation offices of the Ministry of Culture and Media review the application and issue or refuse the import licence within 90 days. During the decision-making process, the competent authority may request additional information and documentation. The 90-day period commences from the moment the applicant provided the last required information.
A separate import licence is issued for each cultural good. If a shipment contains several cultural goods, the competent authority may decide whether one import licence will cover a single item or multiple items within a single shipment.
All costs associated with the import licence application shall be borne by the applicant.

Revocation of the import licence

The competent authority may revoke an import licence it has issued provided that the conditions under which it was granted are no longer met.