Benchmarks for Archaeology and Heritage Protection 2024 – 2029

Sophie Hüglin & Jean-Olivier Gransard-Desmond, EAA Political Strategies Community
Vibeke Vandrup Martens, EAA Community for Climate Change and Heritage
Mairi Davies, Historic Environment Scotland, Climate Change Policy Manager
Emmet Byrnes, EAA & EAC Community on Farming, Forestry and Rural Land Management
Marianne Mödlinger & Evelyne Godfrey, EAA Community on the Illicit Trade in Cultural Material
Frank Siegmund, German Society for Pre- and Protohistory (DGUF), Vice-President

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For the second time, the European Association of Archaeologists has compiled “Benchmarks for Archaeology and Heritage Protection”.[i] This list comprises the five most pressing topics that fall into the remit of the European Parliament. The political parties running in the EU elections in 2024 will be asked to clarify their position and plan of action regarding these topics to help voters to make an informed decision about whom to vote for.

[i] For the Benchmarks for Archaeology and Heritage Protection 2019 – 2024 see:


During election campaigns, benchmarks are a highly effective instrument to make politicians and political parties aware of archaeology and heritage protection. Before the election date, they are asked for statements regarding a set of burning questions. Their answers are widely published and specially made available to voters with an interest in archaeology to aid them with their decision in the polling booth. After the election, these self-set benchmarks will help to hold politicians accountable for the actions they promised to take.

Frequently, the positive public perception of archaeology and its academic and societal benefits don’t match the political decision-making that affects archaeology. The media love archaeology for its ability to draw audiences curious about its findings, but politicians and investors depict it as a disproportionate bureaucratic obstacle impeding the progress of planning and building. Instead of protecting the archaeological and cultural heritage as an unrenewable resource, many governments do not ratify or fully implement Council of Europe conventions, nor do they adequately prosecute and punish perpetrators.

Election benchmarks ask politicians to make statements regarding sensitive issues; they link the popularity of archaeology with the demands of practical politics. Often, responsible public institutions avoid pinpointing problems, because they feel they must be loyal towards their respective governments. On the European level, the European Association of Archaeologists (hereafter EAA) as an independent organisation unites experts as well as engaged citizens and is therefore able to act as an International Non-Governmental Organisation. On the National level, the EAA needs the support of independent organisations. These can help to translate and implement the election benchmarks within the political arena at the national and state levels. DGUF, the German Society for Pre- and Protohistory, has the longest experience in this respect: the Society has successfully practised election benchmarking in German archaeology since 2009.[ii]

The European Parliament Elections in 2024 offer the possibility to raise archaeology and cultural heritage as core issues within cultural policy in Europe. EAA together with its expert Communities, Advisory Committees and partner organisations has selected five topics to be addressed on the European level:

  1. Addressing climate change challenges for cultural heritage
  2. Protecting the historic environment in planning
  3. Addressing the trade in archaeological material
  4. Facilitating mobility of labour across borders
  5. Free use of images related to cultural heritage


I. Addressing Climate Change Challenges for Cultural Heritage

Climate change has an impact on preservation conditions and causes conflicts with all international treaties stressing the importance of cultural heritage (e.g. UNESCO 1972).[iii] It particularly clashes with the intentions of the Valletta Treaty of 1992, which advocates that as many archaeological sites as possible should be left undisturbed, in situ, where they are.[iv] If climate change makes continued preservation impossible, new strategies in heritage management are necessary. Legislators will need to change the practice of national and federal legislation, or even the laws themselves, to prioritize investigation and documentation of sites at risk.

Past societies and their traditions teach us strategies for how to deal with climate change. A recent example of cultural heritage knowledge as a driver to lessen the impacts of modern climate change is the reopening of medieval irrigation systems in Spain, leading water slowly from the mountaintops through the landscape, ensuring that water is distributed over larger areas than by using modern irrigation systems. Further examples can be found in the SACC statement from 2021,[v] in the latest IPCC reports,[vi] and in publications of the Climate Heritage Network.[vii]

To lessen climate change’s impacts, a transition to sustainable energy production is necessary. In this sense, the European Commission is addressing climate change with its Green Deal.[viii] To provide additional protection to cultural heritage it needs the adaptation and implementation of the Valetta Treaty and the WFD of the year 2000.[ix] Both serve as a reminder that a holistic approach is necessary where cultural heritage is included early in planning processes alongside natural heritage and other values.[x] Further climate action plans should be developed based on the European Standard 17652[xi] and aligned with the 17 UN SDGs.[xii]

From an archaeological, deep history or longue durée perspective, only renewable energies can be considered sustainable. Therefore, nuclear power isn’t a safe energy source. So far in human history, no civilization has lasted more than about 1000 years. Nuclear waste needs to be stored for 100,000 years before it is not dangerous anymore. Thus, the problem would be passed on to the coming 3333 generations in a world with social unrest, ongoing wars, and a changing climate.

The positioning of renewable energy sources like wind turbines and solar panels will have to be rethought. On the one hand, planning processes must be sped up to make the green transition possible; on the other hand, heritage assets above and below ground should not be disregarded or destroyed in this context. Such planning needs a holistic process that includes consideration of both natural and cultural values. We propose to integrate a Climate Action Plan for heritage at risk within the 2030 Climate Target Plan of the EU.[xiii]

Questions to topic I:

What does your party plan to do in the next legislative period regarding climate change’s impacts on cultural heritage, and the green transition and its impacts on heritage site preservation?

  1. We will work to implement nature-culture solutions and harmonise legislation and practice in this way overall EU countries, implementing Standard EN17652:2022 and working with the UN Sustainability Goals on developing Climate Action Plans.
  2. We will start an initiative to harmonise legislation and practice in accordance with both the Valletta Treaty and the Water Framework Directive.
  3. We won’t change anything within actual legislation and practice.
  4. (Possibility to write a more differentiated answer, max. 500 words)


[iv] European Convention for the Protection of the Archaeological Heritage (Revised) Council of Europe, 1992 (also called: Malta Convention/Valletta Treaty):

[v] Kiel SACC Summit Statement Social Archaeology & Climate Change, 7th September 2021: and almost identical but without examples




[ix] Water Framework Directive:

[x] See Granberg M. et al. 2022, Effects of Climate-Related Adaptation and Mitigation Measures on Nordic Cultural Heritage. Heritage 5, 2210-2240.

[xi] Standard on cultural heritage monitoring 17652 (2022):

[xii] UN Global Goals for Sustainable Development (2015):


II. Protecting the Historic Environment in Planning

Archaeological heritage is an integral part of the environment and critical to EU citizens’ quality of life. The Council of Europe’s Landscape Convention (ELC) recognises landscapes as contributing to the formation of local cultures, as a basic component of European heritage and as an important factor in individual and social well-being.[xiv] It also mentions agriculture, forestry, extractive industries, infrastructure, and recreation developments as key agents in their transformation.

Here, the term landscape includes rural and urban, prehistoric, historic, and modern, dryland as well as submerged and waterlogged components. The heritage aspect includes both standing monuments and superficially invisible archaeological remains. As the archaeological record is a non-renewable resource, signatory states to the ELC commit to implementing landscape protection into their regional and town planning, as well as other policy areas with an impact on the landscape, such as agriculture. However, many Member States still need to fully implement principles and commitments made in the ELC.

The EU has also amended its Environmental Assessment Directives and endorsed the relevant Council of Europe Conventions (e.g., Valletta, Faro, and the ELC). Additionally, a new European Standard has been implemented to monitor damage and decide on mitigation actions.[xv] The Environmental Impact Assessment (EIA)[xvi] and the Strategic Environmental Assessment (SEA)[xvii] Directives play an important role in protecting the historic landscapes of Europe and within them the cultural and archaeological heritage. Both are a cornerstone for achieving the common societal goal of archaeological heritage protection and management against widely varying local situations and approaches. The EIA Directive, in particular, was amended in 2014 to link landscape more closely with cultural heritage,[xviii] and has had a major positive impact on European archaeology. It has led to the discovery and investigation of large numbers of new archaeological sites and materials. A comparison of approaches across the EU indicates that implementation differs greatly. A harmonisation is necessary to achieve equitable competition in the internal market and act as baseline protection of the historic environment.

With the implementation of the EIA and SEA Directives, we see the following problems:

  • Under the polluter pays principle the funding of mitigation measures is the responsibility of the developer, but it also needs public resources. Currently, the financial interests of developers and landowners seem to have greater weight than heritage protection in planning processes, even in countries that have ratified the ELC.
  • The EIA Directive automatically applies to major projects (listed in Annex I), such as long-distance motorways. Many other projects not necessarily minor in their impact (listed in Annex II) fall under a case-by-case evaluation or threshold criteria set by each EU or EEA Member State. Developers and public authorities can seek to avoid EIA by project-splitting. Some municipal projects, such as housing developments, are entirely excluded from EIA.
  • Where projects cross or are close to the national borders – especially when not only EU but also EEA and/or non-EU Member States are involved – public and planning authority consultation is limited. This is because the list of projects covered by the Espoo Convention on transboundary EIA and its Kyiv Protocol on SEA is more restricted.[ixx]
  • The SEA Directive has not been amended to link it to the relevant Council of Europe Conventions.[xx] NGOs do not have access to a review procedure before a court of law to challenge plans. Therefore, the SEA Directive could be used to assess “renewables acceleration areas”, like wind farms, limiting the grounds for future legal challenges because of simplified and faster permit-granting processes of ‘overriding public interest’.[xxi]

Questions to topic II:

How does your party position itself in the conflict of interests between protecting the EU’s historic landscape in planning processes?

  1. We will campaign for (the ratification and) full implementation of the ELC in our national (or/and federal) planning legislation.
  2. We will extend the EIA Directive to projects currently falling outside because of type or scale. We will limit the capacity of Member States to remove Annex II projects from screening through inappropriate thresholds and introduce a requirement for an examination of the potential effects of all minor (Annex II) projects in line with the ELC.
  3. We will amend the SEA Directive to link it to relevant Council of Europe Conventions and provide NGOs with access to a review procedure.
  4. We will introduce that projects subject to EIA and close to borders must involve public and planning authority consultation without distinction between EU and non-EU States.
  5. We prefer the EIA and SEA Directives to stay as they are and do not see value in implementing the ELC in our national legislation.
  6. (Possibility to write a more differentiated answer, max. 500 words)

[xiv] Council of Europe Landscape Convention (ETS No. 176), opened for signature at Florence on 20 October 2000.

[xv] “Cultural heritage. Assessment and monitoring of archaeological deposits for preservation in situ” (EN 17652:2022)

[xvi] Directive 2011/92/EU of the European Parliament and of the Council of 13 December 2011 on the assessment of the effects of certain public and private projects on the environment, as amended by Directive 2014/52/EU of the European Parliament and of the Council of 16 April 2014.

[xvii] Directive 2001/42/EC of the European Parliament and of the Council of 27 June 2001 on the assessment of the effects of certain plans and programmes on the environment.

[xviii] Recital 16 of the Directive 2014/52/EU expressly links the protection and promotion of cultural heritage comprising urban historical sites and landscapes with the definitions and principles developed in relevant Council of Europe Conventions.

[ixx] The 1991 (Espoo) UNECE Convention on Environmental Impact Assessment in a Transboundary Context (ECE/MP.EIA/21/Amend.1) and its 2003 (Kyiv) Protocol on Strategic Environmental Assessment (SEA) (ECE/MP.EIA/SEA/8).

[xx] The European Convention for the Protection of the Archaeological Heritage (also known as Malta Convention or Valetta Treaty), the Convention for the Protection of the Architectural Heritage of Europe (Granada Convention), the European Landscape Convention (Florence Convention), and the Framework Convention on the Value of Cultural Heritage for Society (Faro Convention).

[xxi] Communication from the Commission to the European Parliament, the European Council, the Council, the European Economic and Social Committee and the Committee of the Regions - REPowerEU Plan (COM (2022) 230 final).

III. Addressing the Trade in Archaeological Material

Archaeological heritage is an integral part of the environment. In situ buried archaeological artefacts form a non-renewable resource. Preservation in situ is a fundamental premise of the “Convention for the Protection of the Archaeological Heritage of Europe (1992)”, commonly known as the Valletta Treaty. The importance of preservation in situ is reinforced in the new European Standard on Cultural Heritage, EN 17652:2022, “Assessment and monitoring of archaeological deposits for preservation in situ”. Preservation in situ is the most effective method for the conservation of archaeological remains. Metal detecting has the opposite effect, removing artefacts from their burial environment without context.

Once artefacts are removed from their stable burial environment, the preservation state of objects that have remained intact for centuries can deteriorate rapidly. When excavation of artefacts is unavoidable, the burial context must be recorded in detail, as the contextual information is what provides us with the narrative of the object. The sale of metal-detected artefacts through various Art Market channels presents a large-scale ongoing threat to our heritage. Metal-detected artefacts can potentially be sold with a forged provenance. This constitutes the crime of fraud.

To bring an end to the trade in archaeological material, it is necessary to improve regulation of both strands of the contemporary Art Market, i.e., sales conducted by ‘legitimate’ established dealers and auction houses, and also the flourishing online trade, including sales conducted on social media. Organised crime networks engaged in the trafficking of cultural heritage often do this in addition to other illegal activities.

Since the introduction of the 1970 UNESCO Convention[xxii] many EU Member States have had measures in place to stop the illicit trade in antiquities on the legal art market. Nonetheless, every year thousands of artefacts are recovered from attempted transactions or during raids when sites are looted. Already, Council Regulation (EC) 116/2009 on the “Export of Cultural Goods” prohibits the export of certain materials from the territory of the EU without a valid licence. This could be amended by the inclusion of an Annex on “Source and Provenance of Archaeological Material”. Such an amendment can include an EU-wide ban on unregulated metal detection and excavation for personal retention (regardless of the intentions of the private collector) of archaeological objects more than one hundred years old (with a rolling date, as currently specified in EC 116/2009). Along with the development of new European Standards, this will help to address the trade in archaeological material that damages the public well-being by depleting our buried historic environment.

Questions to topic III:

What does your Party plan to do regarding the prevention, investigation, and prosecution of looting and trafficking of archaeological materials?

  1. We recognise archaeology as a common good and will take action to discourage private ownership of archaeological objects within the EU; for example, through the development of up-to-date standards on heritage protection. Harmonisation of EU legislation can be advanced by amendment of the Council Regulation on the “Export of Cultural Goods” and through the development of up-to-date standards on heritage protection.
  2. We will encourage EU member states to deliver on commitments on metal detecting they have made under the Valetta Treaty. Financial resources should be allocated to the relevant authorities for the implementation, monitoring, and enforcement of a metal-detecting license and registration system.
  3. We support unregulated metal detecting of archaeological materials for private ownership and trade within the current legislation of each EU Member State. We will support research and outreach on heritage crime.
  4. (Possibility to write a more differentiated answer, max. 500 words)

[xxii] 1970 Convention on the Means of Prohibiting and Preventing the Illicit Import, Export and Transfer of Ownership of Cultural Property. The 2017 Council of Europe Convention on Offences relating to Cultural Property (CETS No. 221), also known as the Nicosia Convention, repeats the content of the 1970 treaty without any notable change.

IV. Facilitating Mobility of Labour Across Borders

The freedom of movement of persons is one of the fundamental four freedoms of EU citizens. In archaeology, this has become increasingly important, due to the way services are rendered.

Since 1990, state services for archaeology have been scaled back in most European nations. Instead, governments and their agencies increasingly take a regulatory role while actual protection and management are conducted by private companies and professional consultancies. Funding of preventive archaeology now mostly is provided through developers based on the polluter-pays principle. This links the requirement for archaeological labour directly to the inherently volatile development market with its economic cycles of boom and bust. This makes long-term planning of required staffing levels difficult and increases the need for mobility across borders.

While mobility across borders of labour is already ongoing, there are still barriers to the free mobility of archaeological labour within the EU.[xxiii] Some are due to individual skills (mainly language); others are due to different state (or national) licensing systems and policies, and different qualification systems in archaeology in different European countries. Policy-related barriers particularly affect experienced workers when moving across borders. Often their qualifications are not recognised, and they must start at the bottom of their career again. This makes long-term personal career planning difficult and restrains companies from attracting skilled workers from abroad in times of increased demand.

Major problems for archaeology concerning the mobility across borders of labour are:

  • The lack of a first academic degree in archaeology in some countries.
  • Differences in the content of university degrees and examinations lead to variations in the acceptability of diplomas in other countries or institutions.
  • Differences in the legal definition of an archaeologist (or the lack of such a legal status).
  • Differing structures in the organisation of field archaeology and its personnel. This creates distortions of fair competition in the market for archaeological services.
  • Different licensing systems under Art. 3 of the European Convention on the Protection of the Archaeological Heritage (revised) (CETS 143). This creates unnecessary barriers to the free movement of staff and services across national (and even state) boundaries.

This also means that aspirant archaeologists in some states cannot gain qualifications that will then enable them to work in other EU member states (Aitchison 2009, 26-27).

Questions to topic IV:

Please indicate which of the following statements is supported by your party’s policies:

  1. We support a first academic degree (under the Bologna-System) of archaeology in countries that do not yet have one and aim towards standardisation of archaeology university degrees and/or other professional qualifications towards a single set of qualifications required to practice across the EU.
  2. We support the introduction of a general legal definition of the role of ‘archaeologist’ applicable across all EU member states.
  3. We support the standardisation of archaeological heritage management processes, especially excavations, to ensure fair transnational competition in the provision of excavation services. We aim to introduce licensing systems to break down barriers to the free movement of highly qualified archaeological staff and services.
  4. We support national autonomy in matters of cultural heritage and oppose standardisation of laws, policies, and practices across Europe.
  5.  (Possibility to write a more differentiated answer, max. 500 words)

[xxiii] See Aitchison K. 2009, Discovering the Archaeologists of Europe: Transnational Report. Reading: Institute for Archaeologists, 24-28; Aitchison K. et al. 2014, Discovering the Archaeologists of Europe 2012-14: Transnational Report. York: York Archaeological Trust, 33-35.

V. Free Use of Images Related to Cultural Heritage

Researchers such as archaeologists, art historians, historians and others need photographs, drawings and plans of archaeological objects, excavations and sites for their scientific work and publishing. From 2020 onwards, the EU aims for all academic publications to be open-access. In many cases, the scientists are at the same time the authors or creators of the images or have acquired the right to publish from commissioned photographers or illustrators, which allows them to publish open-access. However, often the objects depicted in the photos and illustrations are owned by public institutions like museums, collections, and archives. Currently, these public collections follow very different policies regarding the use of images of cultural heritage in their care: some grant upon request simple and free of cost the use of images, while others are extremely restrictive and ask for very high fees. Sometimes the fees demanded for open-access online publications are by far higher than the actual costs of (re-)production in printed publications. At the same time, personnel and administrative costs within these institutions easily exceed the revenues gained through the fees. Altogether this restrictive practice conflicts with the EU’s intention of open academic publishing.

Questions to topic V:

What does your party plan to do in the next legislative period regarding user rights of images of objects, historical records and sites that are owned by public collections, archives, and museums?

  1. A free licensing of images of objects, historical records, and plans in public or collections, such as CC BY, should be granted as a principle and for free for academic open-access publishing. We will start an initiative to harmonise legislation and practise in this way overall EU countries.
  2. A free licensing of images of objects, historical records, and plans in public or collections, such as CC BY, has to be granted on request for academic open-access publishing. It is possible to demand reasonable fees for demonstrably connected costs. We will start an initiative to harmonise legislation and practice in this way overall in EU countries.
  3. The current practice is legally and ethically correct and constructive: whoever wants to make or use such pictures, must request permission from the institutions and inform them of reason and purpose. The institutions decide for themselves and at their own responsibility about their property and this therefore extends to the granting or denying of such permissions. This also prevents improper use of such images. We won’t change anything within actual legislation and practice.
  4. (Possibility to write a more differentiated answer, max. 500 words)