The impact of Brexit on heritage: impeding workers’ mobility and European cooperation in the fight against the trafficking of cultural objects and endangered species

This article contributes to the understanding of the changes brought about by Brexit in the regulatory framework of the movement of cultural objects and people in the United Kingdom. It analyses the restrictions to the employment of EU workers and their impact on the need for highly skilled workers in the cultural and heritage sector. It then critically examines the revocation of the three EU instruments on the import, export and return of cultural objects (Directive 2014/60, Regulation 116/2009 and Regulation 2019/880) as well as the impact of the revocation of Regulation 865/2006 that dealt with the implementation of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES); an instrument often neglected but essential when discussing the circulation of cultural objects as many are made of, or contain parts of, endangered species. It also discusses the situation on the Island of Ireland since there is no border control between Northern Ireland and the Republic of Ireland but there are controls between Northern Ireland and the remaining three Nations (England, Wales and Scotland) of the UK. Brexit has led to regulatory gaps and loopholes that could be exploited by traffickers. Finally, the authors draw together their different findings to make recommendations that would improve the protection of cultural heritage in the UK post-Brexit which would enable it to fulfil its international obligations while maintaining its leadership in the art market.