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Regulatory Updates

Dear Colleagues,

For the past several weeks, the SNA has been fully mobilised to defend our profession in the face of complex and, at times, concerning regulatory developments.

In a constantly evolving environment, we believe it is essential to keep you informed, directly and regularly, about the actions being taken.

More than ever, we remain by your side.

Thank you for your trust.

Christophe Hioco
Chair of the Legal and Tax Committee

Customs : Alert on U.S. Customs Duties

Following the recent announcements by the Trump Administration, the SNA immediately took action to analyse the potential consequences for our profession, with the support of our specialist legal counsel, Pierre Valentin, and in close cooperation with CINOA.

This analysis indicates that certain sectors of our profession could be directly affected by these customs duties, despite a temporary reprieve.

Although the immediate implementation of these measures has been suspended, uncertainty remains, and significant parts of our activity could be adversely impacted.

The SNA will continue its efforts throughout the negotiation period that is now underway.

On 10 April, we organised an online information meeting for our members. A recording of this meeting is available to all SNA members.

Finally, a comprehensive report was submitted to the French Ministry of Culture to alert the authorities to this significant risk and raise awareness of its practical consequences for our sector.

Meeting with the French Ministry of Culture

On 14 April, the SNA took part in a videoconference organised by the Observatory of the Art Market, attended by Ms Christelle Creff and Ms Claire Chastagnier from the French Ministry of Culture.

This discussion provided an opportunity to present the concerns of art market professionals on several key issues.

Export Certificates (CBC) :

The software project intended to streamline the management of export certificates has been abandoned. This is regrettable for our profession, which had long been awaiting a suitable digital tool. Current processing times, which can extend to several weeks, delay sales, weaken transactions and negatively affect dealers' businesses.

Relations with the United States :

Against a backdrop of growing trade tensions, we stressed the importance of ensuring that the art market is not overlooked during future negotiations. Preserving the free circulation of works of art remains essential to our profession and to France's cultural influence abroad.

Imports from Outside the European Union :

We also alerted Ministry officials to the difficulties faced by many galleries in relation to the new European regulations due to enter into force on 28 June 2025. In an already unstable geopolitical environment, these new rules further increase the fragility of the market, particularly for certain specialisations within our profession.

Imports from Outside the European Union : Changing Rules

Two online meetings were organised in recent weeks concerning the entry into force, on 28 June, of the new European Regulation governing imports of works of art from outside the European Union.

Led by Maître Pierre Valentin, these sessions provided a detailed presentation of the new legislation to help members fully understand its direct implications for the practice of our profession.

Certain areas of the art market are genuinely at risk, and collectors will also be affected by the increased complexity of the procedures.

The SNA is warning of a significant impact, both for dealers and for the international attractiveness of the French art market.

On 14 and 15 April, we organised online information meetings for our members. Recordings of these sessions are available to all SNA members (French and English versions).

VAT and Auction Houses: Continued Vigilance Required

An analysis of several auction invoices has revealed significant discrepancies, and in some cases inaccuracies, in the way VAT is being applied by certain auction houses.

A detailed letter, signed by Xavier Bollotte, Chartered Accountant specialising in the art market, has been sent to SYMEV seeking clarification and calling for a fair and consistent framework for all market participants.

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Syndicat des Négociants en Art
8 rue Saint Marc - 75002 Paris

The Syndicat des Négociants en Art brings together, represents, and supports art market professionals, both in France and internationally.