Comment on DOS-2026-0628-0001

Dear Cultural Property Advisory Committee, I am writing to recommend against the proposed MOU with Romania. The restricted categories are overly broad and will conflict with the interests of groups within the United States, especially that of antique collectors and people in the antiques trade. I encourage the committee to consider more carefully what actually is in need of protection rather than just applying a blanket ban based on year. To mention a specific example, the proposed MOU bans pre-1800 textiles. This is clearly intended to protect ancient Scythian textile fragments, but as written, this will also negatively affect collectors of antique European rugs. Transylvanian rugs, from what is present-day Romania, were extensively exported to Western Europe in the 17th and 18th century and are commonly collected alongside antique furniture from those times. The MOU as written will unintentionally harm the trade in these rugs. I am also worried about the MOU’s effect on coin collectors. As written, there is no exception for coins. Many antique coins minted within the borders of Romania are of low value today and circulate frequently among collectors today. The common Greek coins of Histria and Koson, Roman provincial coins, and medieval and Early Modern coins should all be exempt from the MOU. Similar coins were exempted from the MOU with Italy and that precedent should be applied here as well. The committee should also consider how this MOU will affect access to objects that form part of the heritage of non-Romanian peoples, especially of the Hungarian minority that in former times was very numerous in what is now western Romania. There are hundreds of thousands of Hungarian-Americans with ancestry in that region and they should be allowed to buy antiques made by their ancestors.