Spanish auction house avoiding need for export permit?

[DonnaML]

About a year ago, I stopped bidding with Spanish auction houses because of the long delays resulting from the need for obtaining an export permit, plus the fact that the USPS doesn't track shipments from Spain so it's impossible to trace a package after it leaves the country, plus my bad experience with one coin I won from Cayon Subastas getting lost in the mail even after the very long delay for obtaining a permit. (Fortunately, I received a refund.)

But I recently relented, and bid and won a coin from Lucernae -- a Spanish dealer from whom I'd previously made retail purchases on VCoins, but had never tried to buy anything at an auction -- in a Biddr auction. After making payment, I was surprised to receive an email from Lucernae stating the following, in relevant part:

"I have received your payment and all is in order. We will proceed with shipping tomorrow morning (since one year or so we are not working longer with the Culture Ministery bureaucratic process because it is so long in the time, usually 40-50 working days!!). So, I will be operating with my own documents for export and I received the export licenses directly from Customs without the Culture participation. All is so fast and good by the moment, operated by Fedex for U.K. and U.S.A."

The coin was shipped the next day, and according to Fedex it should arrive on Tuesday.

My question is, how does Lucernae manage to avoid the "Culture Ministry bureaucratic process," and what does it even mean that it obtains the export licenses directly from Spanish Customs without the Culture Ministry's participation? I know I shouldn't look a gift horse in the mouth, but I don't really understand this.

 

[expat]

40 minutes ago, DonnaML said:

About a year ago, I stopped bidding with Spanish auction houses because of the long delays resulting from the need for obtaining an export permit, plus the fact that the USPS doesn't track shipments from Spain so it's impossible to trace a package after it leaves the country, plus my bad experience with one coin I won from Cayon Subastas getting lost in the mail even after the very long delay for obtaining a permit. (Fortunately, I received a refund.)

But I recently relented, and bid and won a coin from Lucernae -- a Spanish dealer from whom I'd previously made retail purchases on VCoins, but had never tried to buy anything at an auction -- in a Biddr auction. After making payment, I was surprised to receive an email from Lucernae stating the following, in relevant part:

"I have received your payment and all is in order. We will proceed with shipping tomorrow morning (since one year or so we are not working longer with the Culture Ministery bureaucratic process because it is so long in the time, usually 40-50 working days!!). So, I will be operating with my own documents for export and I received the export licenses directly from Customs without the Culture participation. All is so fast and good by the moment, operated by Fedex for U.K. and U.S.A."

The coin was shipped the next day, and according to Fedex it should arrive on Tuesday.

My question is, how does Lucernae manage to avoid the "Culture Ministry bureaucratic process," and what does it even mean that it obtains the export licenses directly from Spanish Customs without the Culture Ministry's participation? I know I shouldn't look a gift horse in the mouth, but I don't really understand this.

 

Like many things here in Spain, laws and regulations of certain subjects are written in an ambiguous fashion. There are options for many things but the message that comes from above is stated in such a way that the majority of the population believe it is the only way. A company can register as an import/export business, once accepted they can apply for their own export licenses to ship goods outside of the EU financial zone. The number of restricted goods is a lot less through customs than through the Cultural Ministry. I think it is to do with what is called a Single Application Document.

[Nerosmyfavorite68]

Hmm, I might actually put this Spanish dealer on my to-buy list.

One wishes they'd all do this. There's a handful of coins on vcoins that I'd really like from Spanish dealers, yet I don't buy them, because they're from Spain.  There's been a couple of coins which I wanted from Israel - same reason.  And then there's Italy. That's really fair that they ship to the EU, but not the U.S. 

These cultural ministries should just be honest; expensive items are the only ones which they really care about. Exempt anything under $1500 from this farce.

[Ocatarinetabellatchitchix]

I won two coins in the last Lucernae auction, they just told me the payment have been received and the package was on its way by Carrier Correos Internacionale. No mention of export licence for shipping in Canada…

[Prieure de Sion]

4 hours ago, DonnaML said:

My question is, how does Lucernae manage to avoid the "Culture Ministry bureaucratic process," and what does it even mean that it obtains the export licenses directly from Spanish Customs without the Culture Ministry's participation? I know I shouldn't look a gift horse in the mouth, but I don't really understand this.

Honestly Donna - not at all. 

If you take a closer look at the papers of Jesus Vico, Aureo Calico or Tauler & Fau - you will see that they are genuine documents from the authorities. And yes - this takes a very long time, usually around 6 weeks. Now in spring with Easter and Whitsun even longer because of the many holidays. 

Then you look at the "documents" from Lucernae. Nice little pieces of paper from their own printer. That's all I have to say. But it should be clear. 

There is no (!) exemption in Spain. Even a 100 euro denar needs this export licence. And there is no quicker way either. Otherwise it would be absolutely no problem for the big companies like Tauler & Fau and the others to use these exceptions. But they can't. They don't do it either. Even for a 50 euro denarius you have to wait 6 or more weeks for the real documents.

No dealer or auction house in Spain gets official documents the next morning or the morning after 😉 

[DonnaML]

15 minutes ago, Prieure de Sion said:

Honestly Donna - not at all. 

If you take a closer look at the papers of Jesus Vico, Aureo Calico or Tauler & Fau - you will see that they are genuine documents from the authorities. And yes - this takes a very long time, usually around 6 weeks. Now in spring with Easter and Whitsun even longer because of the many holidays. 

Then you look at the "documents" from Lucernae. Nice little pieces of paper from their own printer. That's all I have to say. But it should be clear. 

There is no (!) exemption in Spain. Even a 100 euro denar needs this export licence. And there is no quicker way either. Otherwise it would be absolutely no problem for the big companies like Tauler & Fau and the others to use these exceptions. But they can't. They don't do it either. Even for a 50 euro denarius you have to wait 6 or more weeks for the real documents.

No dealer or auction house in Spain gets official documents the next morning or the morning after 😉 

What about the method described by @expat?

[Prieure de Sion]

9 minutes ago, DonnaML said:

What about the method described by @expat?

The company is very creative. I trust the original documents sent by the reputable companies like Tauler & Fau, Jesus Vico and Aureo Calico. Someone who prints documents on his own printer and calls them official documents... I don't know.

Perhaps there is a loophole in the law. Maybe something can be circumnavigated. I know that reputable Spanish auction houses don't do this. They could do it - but they don't - why? I think Tauler & Fau also know about the possibility - but don't do it - why?! I am not a friend of companies that exploit certain "grey areas".

 

Edited June 4, 2023 by Prieure de Sion

[DonnaML]

34 minutes ago, Prieure de Sion said:

The company is very creative. I trust the original documents sent by the reputable companies like Tauler & Fau, Jesus Vico and Aureo Calico. Someone who prints documents on his own printer and calls them official documents... I don't know.

Perhaps there is a loophole in the law. Maybe something can be circumnavigated. I know that reputable Spanish auction houses don't do this. They could do it - but they don't - why? I think Tauler & Fau also know about the possibility - but don't do it - why?! I am not a friend of companies that exploit certain "grey areas".

 

I take it that you have made purchases from Lucernae, and that's how you know what its export papers are like? 

When my package arrives, I will post about what the export documents say.

 

[expat]

I would be interested to see it too. There are 8 uses for a SAD (Single Application Document) and 1 of them is to tick the Ex box for exports outside the EU fiscal zone. It is an online application which you then print out. It could very well be that they are playing a bit fast and loose with the regulations. We will see

[Prieure de Sion]

This is an official export document from the authorities in Madrid / Spain - with a registered export number (!) - delivered via Tauler & Fau.

Important! You get two documents from Tauler & Fau (Jesus Vico, Aureo Calico etc.)! One is the official export certificate of the authorities shown here and another certificate that guarantees the authenticity of the coin. I have only included the export documents here as a screenshot - the certificate of authenticity is yet another document (not shown here).

 

 

And this one is the only "document" you get from Lucernae. I get many coins last year and not so many coins this year from Lucernae. And every time it was this "document" added. Only this paper (half DIN A4). This is the only document you get from Lucernae with the coin. And since the export permit must be included with the export from Spain, this is probably also the official document (and if not - then he has no export document).

 

 

 

[DonnaML]

On 6/4/2023 at 7:42 PM, Prieure de Sion said:

This is an official export document from the authorities in Madrid / Spain - with a registered export number (!) - delivered via Tauler & Fau.

Important! You get two documents from Tauler & Fau (Jesus Vico, Aureo Calico etc.)! One is the official export certificate of the authorities shown here and another certificate that guarantees the authenticity of the coin. I have only included the export documents here as a screenshot - the certificate of authenticity is yet another document (not shown here).

 

 

And this one is the only "document" you get from Lucernae. I get many coins last year and not so many coins this year from Lucernae. And every time it was this "document" added. Only this paper (half DIN A4). This is the only document you get from Lucernae with the coin. And since the export permit must be included with the export from Spain, this is probably also the official document (and if not - then he has no export document).

 

 

 

OK, it turns out that it's not accurate to say that a plain COA is the only document received from Lucernae. The package arrived from Spain via Fedex today -- I'll do a write-up of the coin separately as soon as I get a chance -- and here are the three customs-related pages that accompanied the coin (i.e., not counting the invoice, etc.). One of those pages also includes a COA. It appears that these pages all represent a self-certification of compliance with Spanish customs requirements, on forms and with language that appear to be downloaded from the Spanish Customs website. In other words, the self-certification is similar to what one receives with coins exported from countries like Germany, Austria, and Switzerland. Whether this constitutes a legal method of exporting ancient coins from Spain while avoiding the need to obtain an export permit from the Culture Ministry, I cannot say. I would be very curious, however, to find out from someone here who is fluent in Spanish the gist of the lengthy certification in Spanish on the first page, beneath the COA. I assume it has something to do with Spanish export requirements, because I see what look like references to cultural importance, historical patrimony, etc. Query: if this is not a legal method of avoiding dealing with the Culture Ministry, then why does Spanish Customs allow self-certification of whatever this language states?

Edited June 7, 2023 by DonnaML

[Prieure de Sion]

1 hour ago, DonnaML said:

OK, it turns out that it's not accurate to say that a plain COA is the only document received from Lucernae. The package arrived from Spain via Fedex today -- I'll do a write-up of the coin separately as soon as I get a chance -- and here are the three customs-related pages that accompanied the coin (i.e., not counting the invoice, etc.). One of those pages also includes a COA. It appears that these pages all represent a self-certification of compliance with Spanish customs requirements, on forms and with language that appear to be downloaded from the Spanish Customs website. In other words, the self-certification is similar to what one receives with coins exported from countries like Germany, Austria, and Switzerland. Whether this constitutes a legal method of exporting ancient coins from Spain while avoiding the need to obtain an export permit from the Culture Ministry, I cannot say. I would be very curious, however, to find out from someone here who is fluent in Spanish the gist of the lengthy certification in Spanish on the first page, beneath the COA. I assume it has something to do with Spanish export requirements, because I see what look like references to cultural importance, historical patrimony, etc. Query: if this is not a legal method of avoiding dealing with the Culture Ministry, then why does Spanish Customs allow self-certification of whatever this language states?

Thats "new" Donna - my last order from Lucernae was from 03/2023 - and this documents are not included (the orders before also not). 
Thats very interesting.

I will ask one of my "friends" of a Spanish auction house - and send him the link of this thread.

[DonnaML]

45 minutes ago, Prieure de Sion said:

Thats "new" Donna - my last order from Lucernae was from 03/2023 - and this documents are not included (the orders before also not). 
Thats very interesting.

I will ask one of my "friends" of a Spanish auction house - and send him the link of this thread.

Actually, the form doesn't seem to be new: I checked, and Lucernae sent me a Roman Republican coin in August 2022 (the Volteius snake biga) accompanied by forms with what looks like the same language. Perhaps Lucernae uses different forms to send coins within the EU as opposed to exporting outside the EU?

[Prieure de Sion]

5 minutes ago, DonnaML said:

Actually, the form doesn't seem to be new: I checked, and Lucernae sent me a Roman Republican coin in August 2022 (the Volteius snake biga) accompanied by forms with what looks like the same language. Perhaps Lucernae uses different forms to send coins within the EU as opposed to exporting outside the EU?

The first form (Spanish) could be the export permit (but I don't know Spanish).

The second form is an export form for customs declaration. It only declares the contents of the shipment. I have to fill out something like this when I export coins from Germany that have a value over 1000 euros. 

But the first form should be the interesting one for us Donna. The second form is just something like extended shipping documents. 

---

Ok. I have only received the authenticity certificates from 2021 to now 2023 - so only the one document that I have pasted here as a screenshot.

It could be, Donna, that from Spain to Germany (within the EU) that is enough, you could say.

BUT - if I get coins from Aureo & Calico, Jesus Vico and Tauler & Fau from Spain to Germany - I also have to wait 6 to 8 weeks and there are also the export papers! Why do the other auction houses from Spain to Germany go to the trouble of making European customers wait 6 weeks (or more) when it would not be necessary? 

I am curious about the feedback.