From 1 January 2026, France will abolish the long-standing VAT simplification known as Customs Procedure 42 (commonly “Regime 42”) for non-EU importers. According to customs specialists, Gaston Schul, this change represents a significant shift for those using France as an EU import gateway, particularly for businesses based outside the EU (such as the UK, Norway or Switzerland). Although EU-established businesses are not directly impacted by the end of the simplified regime, all importers should review their French entry-point strategies now.
What is Regime 42 and how has it operated?
Regime 42 allowed importers to bring goods into one EU Member State and immediately dispatch them on to another without paying upfront import VAT. The VAT liability was instead accounted for in the destination country.
For example: a UK company selling goods to a German customer could import into France, clear under CP 42, transport directly to Germany, and pay import VAT in Germany rather than in France.
What changes from 1 January 2026?
- The simplified version of Regime 42 available to non-EU importers will be abolished.
- For non-EU businesses (e.g. UK, Norway, Switzerland) importing via France:
- French VAT registration will be required.
- They must appoint a fiscal representative.
- They must submit periodic French VAT returns for import VAT and intra-EU supplies.
- For EU-established businesses, Regime 42 remains under “normal” intra-EU VAT rules — the change primarily removes the benefit that non-EU importers previously enjoyed.
Who will need French VAT registration?
From 1 January 2026:
- Non-EU businesses importing goods into France will need a French VAT number.
- EU-based businesses may need French VAT registration if they store goods in France, make domestic supplies in France, or are involved in a chain transaction with France as part of the supply route.
- French customs may demand a VAT number in specific circumstances, to ensure proper VAT control and compliance.
Business impact & alternatives
- Global exporters currently using France as their EU import gateway (especially outside the EU) will face additional administrative and financial burdens. They will need to review cash-flow implications, as upfront import VAT may apply unless deferred accounting via a fiscal representative is arranged.
- France may lose some of its competitive edge as an entry-point for non-EU imports.
- Alternative EU entry routes for non-EU importers remain available that still allow VAT deferral/postponement:
- The Netherlands: via Article 23 licence plus fiscal representation.
- Belgium: via the ET 14000 authorisation and fiscal representation.
Five practical steps to prepare
- Review current import routes – identify where Regime 42 is used and assess the cash-flow impact of the elimination of the simplified route.
- Compare alternative EU ports – evaluate options like Netherlands or Belgium for efficiency and VAT deferral advantages.
- Register for French VAT early – if you plan to continue using France, begin now to avoid compliance delays.
- Reassess Incoterms – consider shifting from DDP (Delivered Duty Paid) to DAP or EXW to reduce exposure to French VAT obligations.
- Work with a trusted fiscal representative – select a partner experienced in VAT compliance and representation in France to manage the upcoming changes.
Why proactive action is essential
The end of the simplified regime signals a structural shift in how goods enter the EU via France. Those businesses that act early can preserve cash-flow efficiency, maintain compliance, and avoid operational disruption. Delayed action risks import delays, higher costs and weakened competitiveness.
If you are a non-EU business using France as your EU import gateway, the clock is ticking. From 2026 the simplified route under Regime 42 disappears. You will need French VAT registration, fiscal representation and new logistics options. Even EU-based businesses should review their strategy. Now is the time to act, to ensure your EU trade continues smoothly and cost-effectively.
