On behalf of the Ancient Coin Collectors Guild, this responds to the Notice of a “Initiation of Section 301 Investigations: Acts, Policies, and Practices of Certain Economies Relating to Structural Excess Capacity and Production in Manufacturing Sectors” published at 91 Federal Register 12886 (March 17, 2026). Specifically, we request that the Section 301 Committee recommends that Harmonized Tariff Schedule (HTS) Heading 9705 (Collections and Collector’s Pieces) and HTS Heading 9706 (Antiques) be removed from consideration for any 301 tariff application.
The Ancient Coin Collectors Guild is a nonprofit organization, whose mission is to promote and nurture the free and independent collecting of coins from antiquity through education, political action and consumer protection. The Guild’s goal is to foster an environment in which the general public can confidently and legally acquire and hold, for personal or professional use, any numismatic item of historical interest regardless of date or place of origin. It has twenty-four affiliate member organizations and advocates for the interests of thousands of ancient coin collectors and hundreds of small businesses of the numismatic trade. More information regarding the Guild may be found at our website at accguild.org.
We make this request to remove any 301 tariff application for such historical coins and antiques – which were produced hundreds of years ago -- because it does not deal with or impact current American manufacturing. These coins and antiques are clearly not related to the issues targeted in the Section 301 Commission Investigation, since they are clearly not part of either the current “manufacturing sectors” or “structural excess capacity.”
Indeed, imposing duties on historical coins, that have previously been exempt from such customs duties, will cause disproportionate harm to the micro, small or medium sized businesses that make up the America’s multi-billion dollar numismatic trade as well as to individual American collectors, by disadvantaging them compared to foreign market businesses and collectors who would not need to pay tariffs on these same items.
Imposing tariffs on these categories would also directly conflict with nearly a century of Congressional policy, which was deliberately designed to ensure the duty-free movement of cultural and historical materials. Historical coins, like other cultural goods, are not typically subject to customs duties because our government has generally sought to encourage cultural exchange. Almost 90 years ago, Congress exempted antiques in order to encourage the free flow of artistic and cultural materials into our country.
As detailed in the comments submitted by the International Association of Professional Numismatists of March 23, 2026 -- whose comments we fully support -- the HTS for the U.S. Tariff Act of 1930 established the concept of an “antique” as a handcrafted object 100 years old or older. Thus, the U.S. exempted antiques from duty even before the UNESCO Florence Agreement of 1952, which was intended to “facilitate the free flow of educational, scientific and cultural materials by the removal of barriers that impede the international movement of such materials.” Finally, the long-standing exemption for historical coins under HTS Code 9705 has not change under either President Trump’s reciprocal tariffs or the more recent temporary import surcharge. Rather, historical coins have been treated as exempt “informational materials” under HTS Codes 9903.01.31 and 9903.03.11
In conclusion, we request that the Section 301 Committee recommends that HTS Heading 9705 (Collections and Collector’s Pieces) and HTS Heading 9706 (Antiques) be removed from consideration for any 301 tariff application.
