When Libribot Finds Too Many Books

Are you getting more Libribot matches than you really want?

This is not a problem we expected, but we have, in fact, recently received a handful of emails with requests from users who were unhappy because they were getting too many matches. The source of their discontent: eBay.

This is not, of course, the majority view. Since we started including eBay in our searches last summer we have received many appreciative emails from regular users thanking us for this expansion.  I was, frankly, surprised at how enthusiastic the response was. The number of clicks, and purchases, has, as a result, significantly increased.

While the addition of eBay was applied generally, it is the Libribot matches that have, in particular, increased. While most of our Libribot users have been happy with this, two or three have written to complain about getting too may matches and that eBay was the primary source of their surfeit.  These particular users told us they hardly ever find what they are looking for on eBay and wanted to know if there was some way to eliminate all the eBay items from their Libribot search results.  When they wrote to us about this our answer, unfortunately, was “no.”

But we hate having “no” for an answer (Al especially).   So we (mostly Al) pushed this forward on the to-do list. We have now added another  new feature that provides check boxes for all the sites that Libribot can search. If you don’t want books from a given site (or sites) all you have to do is go to your Account Details page and uncheck its box.  It will look like this:

Unchecking the box for an individual site will tell Libribot to ignore that site when it is searching for books on your want list.  It will not, however, have any effect on the conventional searches you make using the home page form.  The way that works has not been changed.

You also need to be aware that this Libribot site exclusion will apply to all your wants.  If you only want to exclude a site from searching some of your more fertile wants, but still want to leave that site active in searches for other rarer items, then you need to do something else.

You may already be familiar with the exclusion filters that prevent matches on books that include specified keywords.  The same filters will also work with the names of bookselling sites.  For example, if want to exclude eBay matches from your searches then all you need to do is put [ebay] into the keywords field of the Libribot search form.  This will exclude everything that has the word “ebay” anywhere in the description, including the name of the site where the item is for sale. You will have to do this individually for each of the permanent wants you have saved to your Wants Manager. If you have a large number of wants then this could take a long time.  However, if you are like most users with multiple wants you probably find that it is only a small portion of those wants that produced a large volume of unwanted results.  If you set up an exclusion for just those wants you will probably find that your results become quite manageable and you can leave the rarer items unchanged.

However, if you are certain you never want to see any books that are for sale on eBay then you can simply put [ebay] into the “Keyword Filters” box on your Account Details page.  This will prevent eBay matches being made not only by Libribot, but by all the one-off searches you may make manually from the home page.

Of course, these techniques are not limited to eBay.  You can use them to create an exclusion filter for most of the sites we search.  Most, but not all.  For example, using [bibliophile] as a keyword exclusion will filter out all the books from the bookselling site with that name, but it will also exclude all the books where the word “bibliophile” appears as part of the title or description. This might filter out items you actually want.  There are several sites where some caution may be necessary.

We think this new feature will be helpful for many of you.  More are in the pipeline.  If you have any suggestions for other additions please let us know.

Who Owned This? – THE MOVIE

Provenance Meets Big Data – Do they have a future together? by Jim Hinck from The Grolier Club on Vimeo.

If you regret having missed last month’s “Who Owned This?” symposium  at the Grolier Club you can now see the video version that has just been published to Vimeo.

A link to my own contribution is shown above while the full program can be accessed here:

Who Owned This?

I was pleased to be asked to present a paper at the recent symposium “Who Owned This,” sponsored by the ILAB, ABAA and Grolier Club on 5 March, 2019.  The event took place at the Grolier Club with 120 registrants in the audience and, I am told, an early and lengthy waiting list.

The 8 speakers spoke on various subjects relating to the difficult but timely problems faced by booksellers and librarians in connection with provenance, theft and forgery.  I was honored by being assigned the closing position and used it to consider these subjects with a particular regard to the use of databases to protect from theft, recover stolen books and establish provenance. At the end I ventured a few general speculations about how the database technologies of the future may be even more useful for these purposes, including a preview of some of the things that viaLibri will be doing to make use of these technologies. The title of my paper was: “Provenance Meets Big Data – Do they have a future together?

The full symposium was videotaped by the Grolier Club and will, in the future, be available on their website.  I will make an announcement of that here when it happens.

In the meantime, a few colleagues who had not been able to attend the symposium have asked me to send them a printed version of my paper.  On the chance that there might be one or two others who remain curious about what I had to say I have posted the full text of my presentation elsewhere on my blog.  You can read it here:

Provenance Meets Big Data: Will they have a future together?

Comments have been enabled for that page and will be very welcome.

 

More Good News For eBay Fans

Regular eBay buyers (and we have learned that there are many of them) should be happy to hear that we have just expanded our coverage to include eBay sellers in Australia, Canada and Ireland.  This will bring another 3 million books to the roughly 35 million eBay titles we brought online in July when we first began searching eBay.com (U.S.) and eBay.co.uk (U.K.).

Today’s expansion makes it possible to search in one place all 5 anglophone eBay sites.  We know of no place else where that can be done.  (Not to mention the other two dozen international sites we search.).

But it won’t end here. While our English-speaking customers are now fully served, we still have multiple European eBay sites that also beg to be searched. We plan to get those included as soon as possible.

And don’t forget that searching with viaLibri puts important tools and filters into your hands that are unavailable when searching on eBay itself.  For example: do you sometimes search for early items only to be annoyed by a flood of modern reprints that you must endlessly scroll through instead.    Click “No ISBNs” and “No PODs” and viaLibri will  help you cull what you don’t really want.  Or you can filter your results by the exact date range you want. Or sort by publication year. Interested only in books on Chicago from before 1872? Good luck trying that directly on eBay.

This should also be good news for viaLibri users who have recorded their permanent wants in our Wants Manager: Libribot will now also search daily for listings from the the newly added eBay sites. To take advantage you don’t have to do anything.  Your latest matches will be emailed to you automatically.

But if your desiderata have not yet been added to your Wants Manager then this would be a great time to do so.  Those 3 million new items mentioned above are now about to be matched against want lists for the very first time.

Get ’em while they’re hot.

 

viaLibri adds another new source for old books.

We are pleased to announce another addition to the wide range of sources we are search.  Beginning today we are including over 2 million books from the new ChrislandsSearch website.  All these items are for sale on independent online bookstores built and hosted by Chrislands.

In addition to now being searchable with our home page search engine, new items being added to the ChrislandsSearch group inventory will also soon be matched by our Libribot against all the want lists of our registered and Premium Services customers.  If you have wants saved to our Wants Manager you may soon start receiving matches from hundreds of ChrislandsSearch booksellers.

Of course, if you don’t yet have any wants stored in your Wants Manager then we will have nothing exciting to report.  So maybe this is finally the time for you to create a want list and discover the power of Libribot.

 

A better way to “Buy It Now” on eBay.

We are pleased to announce that viaLibri now includes books from eBay as part of its search results.  If you look in the “Where to Search” panel in the upper right hand corner of our home page search form you will see two check boxes for eBay.com and eBay.co.uk. When these have been ticked the old, rare and out-of-print “Buy It Now” book listings from those two sites will be added to all the items from all the other sites we already search.  This means that over 30 million more items have now become searchable.

And there are more to come.  We expect to start searching auctions on eBay in the near future and plan to expand to other international eBay sites as well.

But beyond just adding numbers to our search results we are also creating a better way to search eBay for books.  You can now use viaLibri to search for books on eBay in ways that are not possible on any other site, including eBay itself.  Once you have given us a try we are confident you will not want to go back to whatever you did before.  Here are some of the things you will now be able to do, for the first time, when searching for books on eBay:

Authors: What could be more essential to the identity of a book than the name of its author?  Nothing that we can think of.  When a book is listed on eBay the author’s name is just another undifferentiated tidbit of information. Searching specifically by author is not possible.  To overcome this limitation we have developed techniques to extract the author’s name from most eBay book descriptions . This means, for example, that if you wanted to search for books written by Martin Luther you could have results that were not also cluttered with books about him. You can also combine this with our exclusion feature to make sure that your search for books by Martin Luther did not also fill your results with books by or about Martin Luther King.  This is something you cannot do when searching on eBay itself.

Publication Dates: The year in which a book was published is, of course, an essential element in determining its interest and value.  One of the most useful tools that viaLibri offers to collectors is the ability for search for books within a specific date range and to sort results by date.  If you are only interested in books on a subject before a certain date we can filter your results to eliminate the things you don’t want. This is something else you can’t currently do when searching on eBay directly.

Fuller descriptions for search results: Native search results on eBay show only a title, price and photo for the books that are returned.  To see any details you need to click through to another page.  Our results will in most cases show, in the results list,  the notes or condition information provided by the seller.  In this way, much needless clicking is avoided.

Bookseller easily identified: In addition to details about the book, our results list will also give the name of the seller who is offering that item, this helping to identify favoured sellers and eliminating what should be an unnecessary click.

First Editions:  We have built our own eBay tool to find books which have been identified by their sellers as first editions. After testing the results we have found that we usually return significantly more eBay firsts when we search on viaLibri than when we search on eBay itself.

Signed copies:  The same thing applies when we search for signed copies.  In fact, with signed books we do even better than with first editions.  In one case, for example, we turned up 3 signed copies of books by a particular author, while eBay had none, and did not even get an option for trying.  If your collecting interests are focused on signed copies we should be able to help you find more of them.

Clipboard: The viaLibri clipboard is available for saving details of items you have found on eBay, along with items from any of the other sites we search.  Even after the book is sold or withdrawn, the information about it will be stored indefinitely for future reference, or until you decide to delete it.

Exclusions:  When searching on viaLibri you can specify words or phrases that help identify items that you want to exclude from your search results. eBay lets you use a single word in the title to select items for exclusion; viaLibri lets you use multiple words or phrases, and the exclusions can be applied specifically to the author, title or keyword fields. For example, this would be useful if you were searching for books about Charles Darwin but did not want books written by him. This can be easily done with viaLibri, but is impossible when searching directly on the eBay site itself.

No ISBN: A checkbox on the viaLibri search form lets you filter out books which have ISBN numbers. This is useful for identifying and excluding modern reprints of early editions when it is only the early editions that are of interest.

Translation:  When an item is described in a foreign language you can use the viaLibri translation feature to translate the text into the language of your choice.

If you are only interested in looking for books on eBay then we feel quite confident that viaLibri is the best way for you to do it.  All you need to do is go to the “Where to Search” panel and uncheck all the options except “eBay (UK)” and “eBay (US).” But why would you want to do that?  We have over two dozen other boxes you can check that will lead you to books from many thousands of additional booksellers from around the world.  eBay is an excellent place to look for books, but if it is the only place you have been looking so far, then I think you are in for a pleasant discovery.

If you are, on the other hand, a long time hard-core eBay buyer then I think you will also be in for a pleasant surprise.  Give it a try and see for yourself if we don’t make your hunt for books on eBay both easier and more productive.

 

Now We Have Amendments to the EU Cultural Goods Regulations. Manuscript Buyers Take Heed.

Back in March I posted here a series of blog posts concerning  proposed EU regulations for the importation of “cultural goods.”  The official objective of these regulations was to combat the looting and destruction of important cultural sites  and to prevent the financing of  terrorism through the trafficking of stolen cultural goods and artefacts.  Early books and manuscripts were included among the objects that were targeted by these new rules even though no one I have heard from has yet seen evidence of terrorist finance activity in the rare book market.  

Needless to say, there was a great deal of concern in the antiquarian book market once the details of the proposed regulations became known and understood.   The alarm, however, was somewhat relieved by the fact that the next stage in the process would allow for amendments to the initial proposal and that there was acknowledgement among at least some of the people involved that major changes needed to be made.

Well, changes are, indeed, afoot, but whether they improve or worsen the situation probably depends on the age and value of the objects you are interested in and whether they are most often books or manuscripts. For booklovers the extent of the burdens may, indeed, be a bit reduced.  But for those who collect early manuscripts (and in some cases not so early) it looks like things will become even worse than originally proposed.

The deadline for making amendments has now passed.  There are at least 381 of them, and I must confess to having skipped over a few. From our perspective, however, the most crucial amendments relate to the ANNEX at the end of the proposal.  This is where they list all the various categories of cultural goods and define which items will be subject to import controls and which ones will not.  There are nine separate proposed amendments, each with a different comprehensive set of rules.  The major change being introduced now is the addition of valuation thresholds,  although a variety of changes to the original age threshold of 250 years are also included.

The different amendments appear to be the work of the different political parties represented on the committee. All but one of them  are proposed by only one, two or three MPs.  For example, Amendment 413, sponsored by the 3 MPs from the European Peoples Party, adds a  €50,000 minimum value threshold for most of the categories, including “old books, documents and publications of special interest ” that are more than 250 years old. This provides some relief for bibliophiles.  However, this amendment leaves unchanged the original proposal as it regards incunabula and manuscripts over 250 years old .

But those amendments are probably all irrelevant.  It is Amendment #408, offered by 6 members of the Progressive Alliance of Socialists and Democrats, which seems most likely, if any, to pass.  This amendment makes several significant changes.  With respect to books, the age threshold is reduced dramatically. Where the original proposal exempted books less than 250 years old, this amendment would reduce the age threshold to only 100 years.  On the other hand, relief is offered by the introduction of a price threshold of €50,000 euros. Whether these two changes would raise or lower the number of books that would be covered is hard to say.  Incunabula, which presumably includes incunable leaves, are still treated separately and will have no price threshold.

The greatest impact, however, will be on manuscripts.  Previously only manuscripts over 250 years old were covered. Amendment #408 would reduce this to 50 years;  and there is no compensating price threshold set.  Any 51 year-old hand-written document would be subject to these rules regardless of value.  There is an exception made for manuscripts belonging to their creators, but this is likely to be a very limited case.

It is extremely hard for me to find any sense here.  The fear that terrorists are financing their activities through the looting and trafficking of old letters and hand-written documents seems obviously groundless. I cannot swear that such a thing has never happened and never will, but the extreme improbability of it balanced against the enormous amount of effort and expense involved in controlling it by these methods makes a complete travesty out of any claim that the authors of the regulations had any real concern for the proportionality that their regulations are supposed to  respect. Much more could be said on this, but it seems unnecessary.

Another serious problem is created by an idea that appears for the first time in the amendments: minimum value thresholds.  These are designed to significantly reduce the number of objects that are covered and thus limit the administrative burden placed on the importers and agencies involved.  At first glance this idea makes sense and seems like an improvement over the original regulations, which were to be applied regardless of value.  However, nothing is said here about how the these valuation thresholds will, in practice, be implemented.  I can imagine only two possibilities.

The first possibility is that the importer would be required to submit an appraisal to prove that his goods fell below the minimum value threshold and were thus exempt from control. As far as I can see, there is no other requirement for a current appraisal as part of the import process.  As a result, what we have here is the rather odd consequence that only the goods that are not subject to regulation will have to submit to the expense and delay of competent appraisal.  And this assumes that the individual who wants to import something will have access to or know how to find someone with the necessary expertise.

The only alternative I can think of would be to have the importer simply declare a value himself,  with or without the needed expertise.  But of what use is that?  If there are, in fact, terrorist manuscript dealers who are hoping to traffic their booty in the EU then I think they will be unlikely to declare the value of their goods to be in excess of the crucial threshold.  In this context self-assessment is meaningless. Only the honest and innocent will be burdened by the rules.

As mentioned, there are 9 different amendments, each with its own age and value threshold.  Some are worse than others. For example, Amendment 416 (drafted by MEPs from the Greens/European Free Alliance) does nothing except to change all the age thresholds from 250 years to 75 years.  From my perspective Amendment 414 seems the least unreasonable, setting a minimum value threshold of €50,000 for books created before 1700 and  for “rare manuscripts and incunabula before 1500 (sic).”  But the lack of a reasonable and effective method for implementing the minimum value threshold is still a fatal flaw.

There is, however, one additional amendment (#417) that does seem reasonable and in more sensible alignment with the professed purpose of the proposed rules.  Daniel Dalton, an MP from the UK, has proposed a second Annex which reads,  simply,  “List of Countries at Risk.”  No details are provided with the Amendment text found on the European Commission site, but one can easily imagine what this might entail.  There already exist restrictions for cultural goods imported from Iraq and Syria.  Import regulation for those countries, and any others under similar terrorist threat,  do make some sense. Whether on not this amendment can, in fact, accomplish that is not clear.  Hopefully it is not too late in the process.  As for the other amendments, I think they fall well short of correcting the deeply flawed regulations they attempted to repair.

 

 

Poll on proposed EU import rules for books and other cultural goods


We have just added to the viaLibri blog an online poll on a question that should be of interest to all our users. It gives them an opportunity to record their opinions regarding European Union regulations, newly proposed, to control the importation of cultural goods, especially early books, manuscripts and prints.

We have also included on the polling page a number of links to documents and articles explaining the issues involved in this important piece of legislation. After you have cast your vote you will have an opportunity to leave your own comments and respond to the comments of others.

If you believe that these issues are important, as we do, then please share our links with your friends and any others who care about  protecting the unrestricted international exchange of early books, manuscripts and prints.

New rules for importing early books and manuscripts into the EU – it will not be fun.

In my earlier post about the proposed EU import regulations I left out a detailed description of the ordeal you will have to go through when importing cultural goods. For most of the dealers I have heard from this is their primary concern. And with good reason.   Although the details have not yet been spelled out completely, from what what I have read so far it seems possible that, for some at least, tranquilisers may be required.

After having now read the documentation several times this is what I understand:

For imports requiring an import licence (this would be incunabula and “rare manuscripts” over 250 years old) the “holder of the goods” must apply for an import licence from a “competent authority.” The “holder of the goods” is defined as the “person who is the owner of the goods or who has a similar “right of disposal” over them or who has physical control of them.” The competent authority, though not defined, will generally be a customs office  that has special competence and training in the evaluation of cultural goods.  These do not yet exist.

In simple cases  this licence application is submitted to the competent customs office along with documentation proving that the goods were exported legally. The competent authority then has 30 days to examine the application and request any additional information or documentation it may feel it needs. Once the application is considered complete the competent authority has an additional 90 days to accept or reject it. When the application is accepted an import licence is issued. The goods may not be imported until the export licence is presented. Since provisions are made for the seizure of goods which enter the EU without a required licence, I assume that the items should not leave the export country until after the export licence has been issued.

Incunable leaf from Gart Der Gesundheit, Mainz 1485. Saw this yesterday at a London book fair for sale for £90. Next year it could require an EU import license to bring it back to Mainz. (Photo courtesy of John Underwood Antiquarian Books)

The application must be made by a “holder of goods,” which means either ownership or physical possession. So if you are an EU resident and want to buy an incunable or early manuscript from an American seller you will first have to pay for your book, leave it in the US, apply for a licence and wait for the licence to be issued. Only then do you have the item shipped. It will have to be received by the right kind of customs office and examined there to make sure that the goods received correspond with the item described in the license. Only then will you be allowed to have your book.

I should note that Article 7 refers to restricting the number of customs offices that will be competent to release cultural goods. This suggests unavoidable difficulties if you happen to live someplace that is far from the right kind of customs office. If you are like me it is unlikely  you will be comfortable having a valuable incunable or manuscript sent to a distant customs office to be examined and then sent back to you in the post. It is not mentioned at whose expense and risk such a shipment would be made.

The situation is only a bit simpler for books (or prints) that are not incunables. These are a separate category which require a self-generated importer statement instead of an import licence. But the problems are similar. The statement also needs to be presented to a “competent” customs office which will physically examine the book to determine that it corresponds with the statement you provided. It may also decide to conduct an “expertise,” which would presumably involve some additional delay. It is, again,  unclear what the regulations anticipate happening in the situation where you live some distance from the right kind of customs office. Does the book get sent directly to customs and held there until your statement is received and your book examined? After that do you need to go to the customs office personally to recover your property, or will it be sent to you in the post?

None of these problems are meaningfully addressed in any of the documents I have read, which leads me to suspect that the people behind it all have yet to figure out a tolerable solution to them.  I know I certainly haven’t.

Or is it possible that the regulations just assume that these steps will all be handled by customs brokers, and they just forgot to mention it? If that is the case, then the situation may be even worse than we imagine.

New EU Anti-Terror Import Regulations Will Target Bibliophiles

If proposed new European Union regulations are approved, European book collectors and dealers may be in for an annoying surprise when they make their first imported purchases in 2019. Starting next year they may become subject to new import regulations that will significantly complicate the process of buying old books, prints and manuscripts from sources outside the EU.  The  purpose of the changes is to combat the looting and smuggling of antiquities and prevent the financing of terrorism through the illicit trade in cultural goods.  While the need for the new regulations is presented almost entirely in relation to the war on terror, the sweeping new rules themselves will be applied comprehensively and include no provisions for exempting goods from areas which are free from armed conflict or terrorist activities.

The new regulations apply to a broad range of cultural goods, but none will be impacted more adversely than books.  The new procedures are as follows:

If a book, engraving, print, document or publication of “special interest” that is more than 250 years old is presented for import in any EU member state the owner or “holder of the goods” will be required to submit a signed importer statement to customs authorities in the country of entry. The statement must include a declaration that the books have been originally exported legally from their source country. However, in cases where the export country (distinct from the source country) is a “Contracting Party to the UNESCO Convention on Cultural Property” then the holder of the books must  provide a declaration that they have been exported from that export country in accordance with its laws and regulations. Needless to say, while the proposal specifies books and documents of “special interest” it does not give any more explicit criteria for defining what this means and the notion of “special interest,” on its own, is sufficiently vague and subjective to include, in practice, virtually any book that someone might want to import.

Register your opinion on the proposed regulations
HERE

More strenuous requirements apply to incunabula and manuscripts that are more than 250 years old. In this case an import license must be applied for and documentation must be supplied to substantiate that the cultural goods in question have been exported from the source country in accordance with its laws and regulations.  When the goods in question are being exported from someplace other than the source country, and the exporting country is a signatory of the UNESCO convention, then the application needs to be accompanied by documents and information substantiating that the cultural goods have been exported legally.  The application must be presented to a “competent authority” (presumably a customs office) which will have 90 days to examine the application and accept or reject it.  The application can be rejected if the applicant is not able to demonstrate that the goods were exported from the source country “in accordance with its laws and regulations.” In the case where the goods are being exported from a country that is a UNESCO Convention signatory, then the application may be rejected if the goods were not exported in accordance with that country’s laws and regulations.  It is tedious to spell them all out, but those are the new rules and we may all need to understand them  very soon.

The regulations are broad in scope and apply to numerous categories of cultural goods besides books, prints and manuscripts. There are exemptions for items less than 250 years old and special provisions for transit and temporary exhibition. Items from all source countries are included and imports from all non-EU countries must be cleared.  There are no value thresholds similar to those generally applied to the export of cultural objects, such as found in  EU Regulation 116/2009.  No distinction is made between commercial and personal property.  There is nothing to indicate that EU citizens may bring their own personal goods into the EU from outside of it without going through the import procedures.  Thus, there is nothing to assure an EU resident who leaves the Union with personal cultural goods in January that he will will be able to return with those goods in February without being subject to import regulations.

All of which might be made to seem like just another of those common annoyances that have become part of post 9/11 life if there was some prospect that it might actual help in the fight against terrorism.  But I doubt that will happen, at least as far as books and manuscripts are concerned.  I don’t doubt that the part of the regulations that target archaeological artefacts, sculptures and artwork could have some impact in reducing the lucrative illicit demand for these objects, for which there is a significant European market.  But books, prints and manuscripts are an altogether different story. The books that have been looted or ransacked by terrorists from libraries in the Middle East were generally of a religious nature and written in Semitic languages, such as Arabic and Aramaic.  The primary market for these books is from Islamic and Middle Eastern buyers who can read the texts and have a cultural connection to them.  If these books are being looted in order to sell them then this is the market that encourages their theft. Obstructing export channels to legitimate european buyers will do nothing to reduce the illicit market that will continue to thrive elsewhere.  The overwhelmingly Western books that will enter the EU subject to these new rules will be irrelevant to the illicit market that finances terrorism.

With respect to books, the controls which have been defined depend on the ability of owners/importers (“holders of goods’) to prove or declare that the imported goods were legally exported from the country in which they were created.  This requirement will be particularly problematic for book and print sellers. Free trade in books has existed since before the invention of printing and the legal undocumented exportation of books has historically been standard practice in all but exceptional cases. Early export documents for books do not exist.  Thus, an individual who seeks to import a pre-1768 book into the EU will either be required to make a signed declaration about facts he is unable to know, or, in the case of incunables, to provide supporting documentation and information it would be impossible to have. Books are inherently portable and created with the anticipation that they will be widely distributed to various parts of the world.  The circumstances under which an individual 18th century book may have been exported from the country it was printed in is almost certain to be unknown. One may assume that its first exportation was legal, but the possibility of smuggling or theft can almost never be absolutely ruled out.  In nearly all cases, a signed declaration affirming that such a book was exported from its source country “in accordance with its laws and regulations” could only be made fraudulently.  

Another remarkable omission is the lack of any exception for the situation where the source country is the same as the country into which the book is being imported. Thus, a German collector wanting to purchase a German incunable from an American bookseller would be required to obtain an import licence and produce “supporting documents and information substantiating” that the incunable had been exported in accordance with German laws and regulations. Even if it is only a €50 topographical print of Munich, the buyer will be required to submit an importer statement with a description of the item and a signed declaration regarding the legality of its initial export from Germany.

Of even greater concern is the fact that the powers created for this new import authority are not just limited to the simple denial of the right to import. Although the implementation details for this are not spelled out in the actual regulation as proposed, the press release issued by the European Commission states clearly that “Customs authorities will also have the power to seize and retain goods [their emphasis] when it cannot be demonstrated that the cultural goods in question have been legally exported.” Thus, seizure will be authorised not just when illegality can be proven, but also when the absence of illegality cannot be proven. I do not think I need to spell out the implications of this newly granted authority.

The sweeping scope of the categories of goods targeted by these regulations is also puzzling, if not disturbing.  They force me to wonder whether the legitimate goal of fighting terrorism hasn’t now been inflated into a general challenge to the entire marketplace for cultural goods of all types. Apart from books and manuscripts, the list of protected categories includes:

  • “sound, photographic and cinematographic archives”,
  • “postage, revenue and similar stamps,”  
  • “original artistic assemblages and montages in any material,”
  • “specimens of fauna, flora, minerals and anatomy.”
  • “objects of ethnological interest,”
  • “objects relating to history, including the history of science and technology and military and social history, to the life of national leaders, thinkers, scientists and artists and to events of national importance,”

Fortunately, for now at least, items less than 250 years old, regardless of category, are exempt. Given that threshold, one has to wonder why the first two categories above have been included at all.  Indeed, given the repeated anti-terrorist justifications for these regulations, one wonders why it was found necessary to include any of the categories listed above. It is hard to dismiss the suspicion that the fight against terrorism, which enjoys broad popular support, is here nothing more than a pretext for the EU to put in place a system of import controls for all cultural goods, regardless of threat, price or origin. Once that framework is securely in place we should not be surprised to see the 250 year thresholds periodically reduced, if not eliminated altogether.  

The 24 page Explanatory Memorandum issued by the European Commission expresses little or no concern for the burdensome impact these regulations will place on the rights of its citizens to purchase and receive cultural goods, such as books and manuscripts, from sources outside the EU. The proposal skips lightly over the extent to which these rules will impede legitimate trade, and ignores entirely the obstacles they will place in the way of individuals who, for example, build rare book collections or engage in historical research.  To my mind at least, these are important activities that support the cultural interests of everyone and should be protected rather than challenged. Surprisingly then, the Memorandum reveals no effort to measure these activities or evaluate how they will be affected by the rules that are to be imposed.  Admittedly, the market for old books is complicated and widely dispersed.  No accurate statistics about its size have been published.  The question of how many books and manuscripts in the open marketplace will be subject to the proposed regulations is ignored.  Although exact numbers are not available, an examination of viaLibri search records tells me that the number of pre-1768 books, manuscripts and prints for sale on the internet must exceed 400,000 items, and is probably even higher than that. It is impossible to know how many of these are sold each year, but I would not be surprised if the number fell safely into six figures. And they would not all be very expensive, as a few test searches on viaLibri would show.  The majority appear to be under $300, and there are even a few that are priced at less than the cost of shipping them internationally.  

The memorandum reports that, during a 3 month assessment process begun  in October 2016, 305 “contributions” were received from “stakeholders,” including “citizens, enterprises, professional associations and interests representatives, NGOs and civil society, [and] public authorities.” It is unclear, however, how many individual contributors are included in that number and who those contributors were.  The International League of Antiquarian Booksellers, we know, was not among them.  Thus, the single largest, oldest and most important professional association in the field of early books and manuscripts was not involved in the assessment process . An omission as serious as that cannot give anyone much confidence in the product of those deliberations.  Fortunately, these regulations have not yet been voted into law and there is still time to save ourselves from them. The ILAB has now sent a letter of concern to the individual members of the European Parliament who appear to have authority on this proposed legislation. These are:

– Daniel Dalton (UK)       http://www.europarl.europa.eu/meps/en/35135.html

– Alessia Maria MOSCA (IT) http://www.europarl.europa.eu/meps/en/124868.html

– Santiago FISAS AYXELÀ (ES) http://www.europarl.europa.eu/meps/en/96729/SANTIAGO_FISAS+AYXELA_home.html

– Kostas CHRYSOGONOS (GR) http://www.europarl.europa.eu/meps/en/125061/KOSTAS_CHRYSOGONOS_home.html

If you also have concerns about this legislation you may want to write to them yourself. I know I intend to.

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