Major Changes to Regime 42 in France from January 2026: Challenges and Opportunities

Beginning 1 January 2026, France will implement significant changes to the application of Regime 42. These updates will particularly affect British and other non-EU companies using French ports and distribution centres as gateways to the European market. While the impact will be felt most by non-EU businesses, the changes may also influence how EU-based companies conduct trade with suppliers from outside the Union, such as the United Kingdom.

What exactly is changing?

Until now, non-EU companies could rely on single fiscal representation, allowing them to import goods into France and move them within the EU without VAT registration in the country of entry. From the beginning of 2026, this option will be abolished.

Non-EU suppliers acting as importers in France (delivering under DDP terms) will now be required to register for VAT in France, submit monthly VAT returns there, and provide more detailed shipment documentation. The simplified fiscal representation and the ability to defer VAT payments via a tax representative will be discontinued.

What does this mean for EU companies?

For EU businesses, this means that their non-EU partners, for example those based in the United Kingdom, will need to either obtain a French VAT number to continue acting as the importer or transfer import obligations to the EU recipient of the goods. If a British supplier chooses the alternative option (DAP instead of DDP), the EU importer will then be responsible for settling import VAT in the country where the goods are delivered.

How can EU companies prepare?

To ensure supply chain continuity and avoid delays after 1 January 2026, EU-based businesses should:

• Review Incoterms and clearly define with non-EU partners who is responsible for the import process and where VAT will be settled.
• Ensure that non-EU partners, such as those based in the UK hold a French VAT number if deliveries continue under DDP terms. This will help prevent shipment delays and customs clearance issues.
• Consider moving import operations to other EU countries, such as the Netherlands or Belgium, where favourable fiscal representation procedures remain available.
• Strengthen cooperation with tax advisers and customs agents to comply with the new documentation and reporting obligations.

What does this mean for EU trade?

The new Regime 42 rules promote greater transparency in goods movements and VAT compliance while enabling better control of cross-border financial obligations. Companies that act early position themselves as reliable partners for UK suppliers, offering efficient customs clearance, stability, and predictability.

We recommend that businesses start preparations now. Early adaption is key to maintaining competitiveness and operational efficiency under the new regulatory landscape.

The Regime 42 changes represent both a challenge and an opportunity, providing a chance to strengthen market position and build even closer relationships with international partners.

Contact us today to get your business ready for the Regime 42 changes and transform them into a strategic advantage.