The 2026 Compliance Landscape
International art shipping has become more regulated. The EU's Fifth Anti-Money Laundering Directive (AMLD5, Directive (EU) 2018/843), which brought art market participants into scope, and updated US customs requirements mean more documentation is needed for every cross-border shipment.
This checklist covers what you need for the three major carriers (UPS, FedEx, DHL) and the most common destination regions.
Universal Requirements
Every international art shipment needs:
1. Commercial Invoice
- Description of each artwork
- Declared value in the currency of the destination country
- HS (Harmonized System) tariff code
- Country of origin — write this on yourself; our invoice carries no origin column and the platform does not determine origin
- Buyer and seller information
2. Packing List
- Number of packages
- Dimensions and weight of each package
- Description of contents and packing materials
3. Certificate of Authenticity
- Proves the work is genuine
- Required by many customs authorities for Chapter 97 goods
4. ATA Carnet (Temporary Imports) — one option, not a requirement
- Optional. A carnet is a convenience document for goods entering temporarily — exhibitions, art fairs, works on loan — that lets them clear without duty or import VAT and re-export against the same paperwork
- It is not the only route. A US Temporary Import Bond (TIB) is a standard alternative for goods entering the United States temporarily, and many destinations have their own temporary-admission procedures. Which is cheaper depends on the number of countries, the number of trips and the value; ask your broker before assuming a carnet
- Carnets are issued by the national guaranteeing association, not by any chamber of commerce you happen to be near. In the United States that is the United States Council for International Business (USCIB); other countries have their own designated body, and some do route it through a chamber. Apply through the correct one, before shipping
Carrier-Specific Requirements
UPS Art / UPS Express
- Declared value on the air waybill MUST match the commercial invoice
- Read the declared-value cap and the extraordinary-value exclusion in the current terms for the service you are booking. There is no universal dollar figure above which separate cover becomes necessary — our insurance guide explains why we do not print one, and a figure named in an earlier version of this checklist was invented
FedEx International Priority
- FedEx International Air Waybill
- Commercial invoice in triplicate
- Proforma invoice acceptable for non-sale shipments
DHL Express Worldwide
- DHL Waybill
- Electronic commercial invoice via DHL portal
- DHL requires HS codes at 10-digit level for EU destinations
Regional Considerations
European Union
- EORI number required for imports
- VAT deferment documentation for temporary imports
- AMLD5 customer due diligence for art transactions of €10,000 or more (AMLD6 is the criminal-law directive and sets no art threshold)
United Kingdom (Post-Brexit)
- Separate EORI for UK (starts with GB)
- Import VAT at a reduced rate for qualifying works of art under Chapter 97 — confirm the current rate and what qualifies before you quote it to a buyer
- Declarations are filed electronically through the Customs Declaration Service (CDS). The old C88 / SAD paper form belonged to the retired CHIEF system and is no longer the route — if a guide or a forwarder still refers you to a C88, they are working from stale instructions
CITES — global, not regional
- A CITES permit may be required for any work containing ivory, tortoiseshell, certain rosewoods and other restricted timbers, coral, or feathers and skins from listed species. CITES is a global convention with more than 180 parties, so this applies to a shipment into Europe or North America exactly as it does to one into Asia. It is not an Asia-Pacific footnote, and treating it as one is how an older work with an ivory inlay gets seized
- Permits are issued by the exporting and importing countries' own management authorities and take time. Raise it with your broker as soon as the material is in question, not when the crate is booked
Asia-Pacific
- Japan requires detailed material declarations for imports
- Australia requires BMSB (Brown Marmorated Stink Bug) seasonal treatment for goods shipped during the declared risk season
How to Stay Compliant
The fastest way to produce customs documentation is to generate it from the artwork record rather than retype it. Gilded Art Works produces a commercial invoice carrying shipper and consignee blocks, one row per work with artist, year, medium and dimensions, an HS code classified per line, and declared values with a total — over a signed declaration. It does not file your entry, calculate duty or VAT, determine country of origin, or tell you whether a CITES permit applies; those are your broker's, and the checklist above is how you brief them. Generate your customs packet now.