If your UK company currently uses the Regime 42 (R42) customs procedure to ship goods into the EU via France, there's a significant change coming that you must prepare for.
Regime 42 currently allows non-EU companies, like those in the UK, to import goods into France and then move them to another EU country without needing a French VAT registration. This relies on using a limited tax representative.
The Deadline and The Change
This efficient process is being abolished for non-EU companies.
- The Deadline: The ability for non-EU companies to use an "ad hoc" limited tax representative for R42 shipments through France ends on December 31, 2025.
- The Change: From January 1, 2026, new French legislation will permanently stop non-EU sellers (including UK companies) from using this limited tax representation for R42. The French Tax Administration is making this change to gain better visibility and is now requiring a full VAT registration in France for non-EU companies.
The Regime 42 procedure itself remains in France, but it will only be available to companies that are already VAT registered in France or are located in an EU member state.
What UK Businesses Need to Do Now
UK exporters using Delivered Duty Paid (DDP) terms through France must have a compliant import solution in place for 2026. You must act before December 31, 2025.
You have two main paths to continue selling to EU clients after the deadline:
- Obtain a French VAT Registration (Maintaining DDP):
- Register for a French VAT number.
- This allows you to switch to the Regime 40 procedure, which uses a reverse charge, meaning no import VAT is paid upfront.
- You can continue to ship under DDP terms and deliver directly to French or EU customers.
- Change Incoterms to DAP (Delivered At Place):
- You change the Incoterms to DAP.
- Your EU customer becomes the importer in France.
- This allows the shipment to remain VAT-exempt in France by leveraging an EU-established business's VAT number. This keeps it "business as usual" for your customer.
Ready to Secure Your Compliant Path?
Getting a solution in place well before the end of 2025 is essential to avoid disruptions to your EU supply chain.
If you want absolute clarity on these upcoming changes and need support to transition smoothly and on time, please do not hesitate to reach out. Contact the Ziegler team today to discuss the best compliant option for your business model.