From 1 January 2026, France introduced major changes to its customs and VAT rules that affect how goods are imported into France from outside the EU. These changes apply to all non-EU businesses, not just UK exporters.

The current position – What is “Regime 42”?

Under the past rules, non-EU businesses could use Customs Procedure Code 4200 (known as Regime 42) when importing goods into France. This regime allowed goods to enter France without paying French VAT at the border, provided the goods were destined for another EU country. It was a useful simplification for businesses shipping goods into France and then onwards within the EU.

What has changed?

From 1 January 2026, France abolished Regime 42 for all non-EU businesses. This means:

• imports into France will always be subject to French import VAT at the point of entry;
• businesses can no longer avoid French VAT by declaring onward movement to another EU member state;
• to reclaim VAT, businesses will need a French VAT registration or fiscal representative.

Who will be affected?

This change affects any non-EU business that:

• acts as the importer of record in France, or
• uses Delivered Duty Paid (DDP) terms for shipments into France, or
• relies on Regime 42 to simplify VAT obligations.

These are alternative conditions, not cumulative. If a business meets any one of these criteria, it will be impacted by the new rules.

To break that down:

• if a business acts as the importer of record in France, it will be affected, regardless of whether it uses DDP or Regime 42.
• if a business uses DDP terms for shipments into France, it will almost always be the importer of record and therefore affected.
• if a business relies on Regime 42 to simplify VAT obligations, it will be affected because Regime 42 is being abolished.

For affected businesses, the practical implications include:

• mandatory French VAT registration for imports.
• increased compliance costs and administrative burden.
• a need to review pricing, Incoterms, and supply chain arrangements.

What about EXW sales?

From a UK perspective, if a manufacturer sells goods on an EXW basis and the buyer collects the goods from the UK premises, this change does not affect the seller. Under EXW:

• the seller’s responsibility ends once the goods are made available at their premises;
• the buyer is responsible for export clearance, transport, and all import duties and VAT in the destination country;
• the seller is not the importer of record in France and therefore does not need to register for French VAT.

What should businesses do now?

• Review your Incoterms: If you currently use DDP for France, consider whether this remains viable.
• Assess VAT obligations: If you will continue importing into France, plan for VAT registration and compliance.
• Update contracts and pricing: Ensure responsibilities for customs and VAT are clearly allocated.

To summarise, the abolition of Regime 42 is a significant change for all non-EU exporters delivering on a DDP basis into France. Those selling on EXW terms are unaffected, but businesses acting as importer of record in France will need to adapt their processes and contracts.

This change currently applies only to France. There is currently no indication that other EU member states are abolishing Regime 42. Regime 42 is an EU-wide customs simplification, but each country administers it nationally and France has chosen to remove it for non-EU businesses from 1 January 2026. Businesses may consider alternative EU entry points if they wish to maintain similar VAT simplification benefits but that would likely require a review of their logistics operation and the impact of such changes.

Other EU countries still allow Regime 42 for now, but France’s move could signal a trend towards tighter VAT compliance across the EU.

Disclaimer: Nothing in this piece is legal advice and the issues covered are non-exhaustive. It is intended to provide information of general interest about current legal issues. Further, any reference to financial or related information is for completeness of the article only and we do not give accountancy or tax advice. As all circumstances are different, you should take specific legal and accountancy advice before acting in reliance on any of the information provided.