# Export Bans and National Treasures: What Happens After the Hammer

> Britain defers, France refuses for thirty months and may decline to buy, Italy prohibits outright. And a British buyer means the machinery never starts at all.
> The Study - 2026-08-02
> Canonical HTML: https://iconotheca.com/study/export-bans-and-national-treasures/

## Key points

- In 2024-25 the Reviewing Committee deferred 18 objects worth GBP 40 million; six were acquired, for a combined GBP 586,132.
- A Hans Coper bottle was lost because the deferral price of GBP 584,200 was itself a hammer of GBP 460,000 plus GBP 124,200 of premium.
- France may refuse a certificate and then decline to buy, in which case the work is released after thirty months.
- Bristol's Turner appeal succeeded and its bid failed, and because the buyer was British no export deferral was ever triggered.

## Three mechanisms that reach three different answers



## The British system: three criteria, a case-by-case clock, and the buyer's own price



## What the numbers look like, and where the premium hides



## France may refuse and then decline to buy



## Italy simply says no



## When the appeal succeeds and the bid does not



The hammer is the middle of the story in these cases, not the end. Any record that treats the sale as the final event will be wrong about where the object is within a few years, and wrong in the direction that matters: a Cimabue reported in 2019 as leaving for a private American collection entered the Louvre in 2023. The Bristol Turner shows the sharper limit. The city raised its money, went to the room and lost, and no export deferral was ever triggered, because the winning bidder lived in Britain. The apparatus for saving national treasures does nothing whatever about a national buyer.

## Questions

**Does an export ban cancel the sale?**

No. Title passes at the hammer and the sale stands. What is restricted is movement of the object. In the United Kingdom that is a deferral of the licence decision; in France a refusal of the export certificate; in Italy, for declared objects, a standing prohibition on definitive export.

**Does the state have to pay market price?**

In the United Kingdom the deferral price is the value declared on the export licence application, which is what the departing buyer paid, so a domestic institution must match that total including buyer's premium. In France the state may make an offer, and if the owner rejects it the price is set by experts.

**Is the state obliged to buy?**

No. The French ministry's own guidance is permissive: within thirty months of refusal the administration may make an offer, and if the state renounces the acquisition the work may then leave. British deferrals likewise lapse when no serious expression of interest is received, which happened in nine cases in 2024-25.

**Which works are at risk of a ban?**

Those judged of national importance. Britain publishes the three Waverley criteria of history, aesthetics and scholarship, and one is sufficient. France classifies goods of major interest for the national heritage from the point of view of art history or archaeology. Italy sets value and age thresholds alongside its declaration procedure.

## Sources

- [1] Arts Council England, 'Reviewing Committee on the Export of Works of Art and Objects of Cultural Interest', on its 1952 establishment, membership and the Waverley criteria. <https://www.artscouncil.org.uk/supporting-arts-museums-and-libraries/supporting-collections-and-cultural-property/reviewing-committee-0>
- [2] Reviewing Committee on the Export of Works of Art and Objects of Cultural Interest, 'Export of Objects of Cultural Interest 2023-24', 69th annual report, November 2024, including the walrus ivory and Hans Coper cases. <https://assets.publishing.service.gov.uk/media/6745c4b1e7cf64050b8098e3/Annual_report_of_the_Reviewing_Committee_on_the_Export_of_Works_of_Art_and_Objects_of_Cultural_Interest_2023_to_2024.pdf>
- [3] Reviewing Committee on the Export of Works of Art and Objects of Cultural Interest, 'Export of Objects of Cultural Interest 2024-25'. <https://assets.publishing.service.gov.uk/media/687e53a292957f2ec567c60b/ACE470_RCEWA_Annual_Report_2024-25_Accessible.pdf>
- [4] Arts Council England, 'Summary of items currently under temporary export deferral'. <https://www.artscouncil.org.uk/creative-matters/news/summary-items-currently-under-temporary-export-deferral>
- [5] Ministere de la Culture, 'Circulation des biens culturels et Marche de l'art', on export certificates, national treasure classification and the thirty-month period. <https://www.culture.gouv.fr/thematiques/musees/pour-les-professionnels/conserver-et-gerer-les-collections/gerer-les-collections/circulation-des-biens-culturels-et-marche-de-l-art>
- [6] Musee du Louvre, collection record for Cimabue, La Derision du Christ, inv. RFML.PE.2023.33.1, giving the Senlis hammer and the classification date of 20 November 2019. <https://collections.louvre.fr/en/ark:/53355/cl010509421>
- [7] Musee du Louvre, press release, 'Deux Tresors nationaux pour le musee du Louvre', 3 November 2023. <https://presse.louvre.fr/deux-tresors-nationaux-pour-le-musee-du-louvre/>
- [8] The Art Newspaper, 'Cimabue kitchen painting placed under export ban ends up at the Louvre', 6 November 2023, reporting the price as understood rather than published. <https://www.theartnewspaper.com/2023/11/06/cimabue-kitchen-painting-blocked-at-auction-ends-up-at-the-louvre>
- [9] Normattiva, Decreto Legislativo 22 gennaio 2004 n. 42, Codice dei beni culturali e del paesaggio, articles 13, 14 and 65. <https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:2004-01-22;42~art13>
- [10] BBC News, 'Lost Turner work sold as museum outbid at auction', 2 July 2025, recording Bristol as the second highest bidder and the return of donations. <https://www.bbc.co.uk/news/articles/cn9y2j4lgzro>
- [11] Museums Association, 'Bristol museum raises 100,000 pounds in five days to bid for Turner painting', 1 July 2025. <https://www.museumsassociation.org/museums-journal/news/2025/07/bristol-museum-raises-100000-in-five-days-to-bid-for-turner-painting/>
- [12] Anna Brady, 'Turner painting bought last year for 500 pounds sells for almost 2m pounds at Sotheby's', The Art Newspaper, 4 July 2025, giving the GBP 1.5m hammer and GBP 1.9m with fees. <https://www.theartnewspaper.com/2025/07/04/%C2%A3500-turner-painting-sells-for-almost-%C2%A32m-in-sothebys-old-master-sale>
