ONE of the aspects of the recent sale of Pontormo's Hal- bardier least discussed outside the U.S. was the loss to the Frick Collection of a work which had for so many years complemented its Bronzino portrait of Lodovico Capponi. It now appears there are moves afoot in the United States to set up a 'not-for-profit' body analogous to the National Art Collections Fund in order to help museums to acquire works of art. American museums have, of course, been adversely affected by changes in the tax laws which make it less fiscally advantageous for private collectors to donate works, and escalating prices have tempted owners of works on loan to museums to withdraw them for sale at auction. Until recently U.S. museums have been depicted as the major predators of European private collections: it will be fascinating to see whether the establishment of this new body will be the first step on the road to export control to protect American museums from the perceived threat from the east.

Meanwhile in Europe none of the diverse systems for controlling the export of works of art is wearing well under the strains of the market. The British government is not alone in seeking piecemeal, ad hoc remedies for indi- vidual cases and elevating them into general principles. The French Ministry of Culture has recently announced that the St Aubin sketchbook from the Ganay/Behague collection has been acquired by an insurance company and deposited for ten years at the Louvre, where it joins Titian's portrait of Alfonso d'Avalos from the same source, on loan under an analogous arrangement. A new govern- ment scheme has been devised to allow insurance com- panies, through fine-art subsidiaries, to buy works of art which may then be quoted as part of their capital assets. Although the sketchbook is now officially described as 'saved' from dismemberment or export, such salvation is not eternal - although the Louvre apparently has an option to buy at any time during these ten years.

Curious as these French arrangements may be, it is in- structive to contrast them with the response by the British government to the embarrassing problem of Canova's Three Graces. After twice extending the deferral of its export licence, the ex-Secretary of State announced changes in the export control procedures - an intention to take into account private bids when deciding whether or not to issue a licence - which have thrown the entire system into disarray and brought the Export Reviewing Committee close to resignation as a body. Although a private bid from 'British entrepreneurs, David and Frederick Barclay' was announced in March, and a licence refused in April, the future of the Three Graces is still unclear, pending a judicial review of the Minister of the Enviroment's decision not to take action on its classification as an integral part of its setting at Woburn Abbey (where the grounds are now scheduled to become an amusement park).

Seven months since the announcement of the new arrangements, no further private offers for export-stopped items have been announced. The next major challenge will be posed by the Badminton Cabinet, the most important piece of furniture sold at auction for many years, which - inexplicably - has not been starred as an outstanding item by the Export Reviewing Committee.

The Museums and Galleries Commission, taking a more polemical stance than is its wont, addresses the Export Reviewing procedures in its annual report for 1990.* The Commission was among the many bodies that advised the Secretary of State earlier this year that offers by a private individual or company to buy an export-deferred item should be accepted only if 'it were the buyer's intention to present it eventually to a public institution in the U.K.' The Secretary of State expressed the view that he could take such intentions into account, but had no powers to enforce them. The Commission now proposes a 'two-tier' process, according to which first option at deferral stage would be offered to a public institution. This could link up with an earlier suggestion by the ex-Minister for the Arts that museums could acquire an 'option to purchase' (presumably at a nominal sum) at the outset of a deferral period, thus making their intentions plain, and, in theory, streamlining the process.

The two-tier system would not, as the report acknowl- edges, meet the philosophical objections to the new ar- rangements in favour of private buyers. However effective they may or may not be in keeping individual items in the U.K. in the short term, such arrangements are unfair to foreign purchasers and untrue to the notion of public interest that underlay the Waverley Report. Would it be impossible for the new Secretary of State for Trade and Industry to acknowledge that his predecessor's initiative was misconceived? At all events, the Commission is surely right to suggest that it would make more sense in future for the decisions on the export of works of art to rest officially with the Minister for the Arts - who would not be able to wash his hands of responsibility for their final destination.

It should be apparent to the new Minister for the Arts that some of these problems could be solved by restoring to the National Museums the purchasing power of their annual acquisitions grants, which have been frozen for six years, and by giving realistic sums to the National Heritage Memorial Fund, which last year had only three million pounds to spend. The creeping paralysis which has over- taken the export review system can be dispelled only by an injection of cash.