Major changes to France's Regime 42: What UK businesses need to know from January 2026
Nick Crouch · Posted on: September 30th 2025 · read
From 1 January 2026, France will implement significant changes to its Customs Procedure 42 (Regime 42), impacting UK businesses engaged in cross-border trade with the EU. These alterations derive from the French Finance Act 2025, which repeals Article 289 A III of the French General Tax Code, effectively ending the "one-off fiscal representation" mechanism previously available to non-EU companies.
What is Regime 42?
Regime 42 has historically allowed non-EU businesses, including the UK, to import goods into France without paying import VAT or registering for VAT in France, where those goods were to then be transported to other EU member states. The onward movement of goods qualified for zero-rating as an intra-EU supply of goods.
Key changes from 1 January 2026
Abolition of one-off Fiscal Representation
The provision that allowed non-EU companies to appoint a "one-off fiscal representative" to handle VAT-free imports into France is being abolished. This change means that UK businesses can no longer use a third party's French VAT number for customs declarations under Regime 42.
Mandatory VAT Registration in France
From 1 January 2026, UK businesses wishing to continue importing goods into France under a DDP Incoterm using Regime 42 must:
- Register directly with the French tax authorities to obtain a French VAT number.
- File their own French VAT returns, taking on full responsibility for tax compliance
France operate automatic “reverse charge of VAT on import”, similar to the UK’s postponed VAT accounting scheme. This means that any VAT due on importation into France will be deferred and paid via the VAT return. The same amount is recoverable (subject to the usual rules) on the same VAT return.
We also note that any sales of goods by a supplier not established in France to French businesses will be subject to the reverse charge mechanism, provided the customer is registered for VAT in France.
What UK businesses should do now: Plan ahead and ensure that all necessary registrations and appointments are completed before the 1 January 2026 deadline to avoid disruptions in trade.
What should you and your business do next?
The changes to Regime 42 represent a significant shift in France's approach to VAT on imports from non-EU countries to those who previously used the scheme. UK businesses must adapt to these new requirements to maintain smooth operations and compliance.
Proactive planning and expert guidance will be essential to navigate this transition effectively.
