What is changing for UK businesses delivering into France?
From 1 January 2026, UK businesses exporting goods into the EU under DDP (Delivered Duty Paid) terms via France, will face changes that will impact VAT reporting.
Key points at a glance
- Regime 42 (CPC 42) currently allows VAT-free imports into France via a limited fiscal representative.
- From 2026, non-EU businesses (including UK companies) can no longer use fiscal representatives under Regime 42.
- UK businesses must either register for VAT in France or change their supply chain setup.
- Alternative options include rerouting via other EU Member States (e.g., the Netherlands) or changing incoterms.
- Supply chains should be reviewed well before the changes take effect.
How the end of Regime 42 impacts VAT reporting
There is currently a Customs Procedure Code (CPC) available, Regime 42 (CPC 42), in order to import goods into France, via a limited fiscal representative. This allows a VAT free import and onward VAT free intra-community delivery to the end customer, where acquisition VAT is declared in the destination EU Member State. By using Regime 42, the seller does not have to register for VAT in France.
The use of a limited fiscal representative is now set to be abolished from 1 January 2026 for non-EU companies, meaning UK businesses will no longer be permitted to use French fiscal representatives under Regime 42. To continue importing goods through France, for onward supply to the EU under DDP terms, UK businesses must register for VAT in France and file French VAT returns.
UK businesses must now understand what the changes mean and how their supply chains must be altered to deal with these changes.
Options for UK businesses after January 2026
One option is to re-route deliveries through another EU Member State, for example, the Netherlands allows fiscal representation for a non-EU business.
However, it may be easier to register for VAT in France and submit French VAT returns, allowing DDP deliveries to continue.
A change of incoterm is another option, in order to make the customer the importer into the EU, therefore avoiding a French VAT registration for the UK business. However, this would need to be discussed and agreed with customers and agreements amended.
Review your supply chain now
The new year will soon be here, so if you currently use Regime 42 for shipments through France, start to review the position and what changes need to be made now.
Please contact a member of the Menzies VAT team, or usual Menzies contact, in order to start your supply chain review. Menzies is well connected in France through the HLB International Network and can provide local advice and compliance services, as required.
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