Call for Comments - Bulgarian Request for Import Restrictions
by Peter Tompa
Please consider sending this to any coin collector you know:
The US State Department is seeking public comment on a new request for import restrictions made on behalf of Bulgaria. To submit comments electronically to the State Department’s Cultural Property Advisory Committee (CPAC), go here:
For further details of the request, see
What is at issue? Despite President Obama’s efforts to foster government transparency, the State Department has not indicated whether coins are part of the request. Nonetheless, based on recent history, it is probable that import restrictions on coins will be proposed. As a practical matter, this means the State Department and US Customs may be considering restrictions on tribal coinages from Thrace, coins of Greek city states like Apollonia Pontica and Messembria, Roman provincial coins struck at Bulgarian mints,and even some Roman Imperial coins. It’s also possible that any restrictions will include later coins as well. Though details are few, the public summary the State Department has provided indicates that Bulgaria seeks import restrictions on objects from 7500 B.C. to the 19th c. AD. If restrictions are imposed on coins, many common types will likely become so difficult to import legally that they will become unavailable to most collectors.
Why bother? Large numbers of coin collectors have made their concerns known to CPAC. Recently, 70% of the comments CPAC received on an MOU with Greece were from concerned coin collectors. Even though recent extensions of import restrictions to certain Greek and Roman Republican coins from Italy and on coins from Cyprus despite the vast amount of public comment make it easy to become cynical, public comment can at least help moderate demands for import restrictions. For example, archaeologists actively sought import restrictions on Roman coins as well during the discussions about the Italian MOU, but they remain exempted, and thus easy to obtain on the open market, likely due to the 2000 or so faxes CPAC received from concerned collectors.
What should I say? Tell the State Department and CPAC what you think about the bureaucracy’s efforts to deny you the ability to collect common ancient artifacts that are available worldwide. You might also might consider noting that coins from Bulgarian mints are common and often very inexpensive. Tens of thousands or hundreds of thousands exist in collections around the world, and because of the low price the vast majority of these coins will never have been through an auction and will have no verifiable provenance.
If you are having trouble commenting from the direct link above, go to http://www.regulations.gov and search on docket number DOS-2011-0115. Further information about regulation.gov, including instructions for accessing agency documents, submitting comments, and viewing the dockets, is available on the site under “How To Use This Site.” Kindly note that your comments will be public so avoid conveying any personal information, and, of course, be polite in commenting on the issue.
Please submit comments just once, before the cutoff of 5:00 PM EST Nov. 2, 2011.
In my view, it would be appropriate for each collector to begin with a complaint to the effect that he or she has noticed that the State Department is ignoring public input and imposing import restrictions upon coins, even though the vast majority of comments have opposed import restrictions upon coins.