France ends VAT simplification for non-EU importers

For decades, Regime 42 has been allowing businesses to route goods into the EU through France without paying import VAT upfront. Its removal, if confirmed, will have far-reaching consequences, particularly for UK exporters post-Brexit, but also for U.S., Asian, and other non-EU businesses that rely on France as their primary gateway into Europe.

But the Finance Act for 2025 – Article 289 A III of the General Tax Code (CGI). included its removal for January 2025. But this was extended on 14 May to a new deadline 1 January 2026. From 1 January 2026 only an EU buyer or their appointed representative can act as the importer under Regime 42

Any withdrawal may nudge importers to instead use the Dutch or Belgium favourable import regimes.  See more background in our French VAT guide.

The new French import VAT deferment scheme remains in operation.

Regime 42 – avoiding import VAT payments and registrations

Regime 42, officially known as CPC 42 00, was designed as a VAT simplification mechanism. It allowed companies to import goods into one EU member state and immediately ship them to another EU country without paying import VAT at the border. Instead, VAT was accounted for in the destination country through the reverse charge mechanism.

The benefits included:

• No upfront VAT – freeing up cash flow.

• EU-wide logistics flexibility – goods could move seamlessly across borders.

• Reduced administrative burden – fewer VAT registrations were required.

In practice, non-EU businesses often appointed a fiscal representative in France to operate under Regime 42. This made it possible to import through French ports or airports, clear customs quickly, and ship onwards into Europe.

Why is France withdrawing Regime 42

The French government is considering that from 2026 it will abolish limited fiscal representation for non-EU businesses. Without the possibility of relying on intermediaries, non-EU companies will no longer be able to use Regime 42 to avoid French VAT registration.

The rationale is twofold:

• Tightening VAT compliance: France has long been concerned about potential VAT fraud and underreporting linked to indirect import structures. Instead preferring the deferred VAT scheme.

• Aligning with EU reform trends: Across the EU, tax authorities are moving towards greater transparency, digital reporting, and ensuring that foreign businesses pay VAT where value is created.

What changes for Non-EU exporters?

From January 2026 Non-EU businesses importing into France will face the following obligations:

• French VAT registration will be mandatory for businesses clearing goods through France.

• VAT returns will need to be filed regularly, declaring import VAT and subsequent supplies.

• Full fiscal representation may be required, adding cost and administrative complexity.

• No Regime 42 relief will be available — meaning goods imported via France cannot bypass import VAT via onward shipment.

For companies that previously relied on Regime 42, this means higher compliance costs, longer lead times, and possible cash flow disruptions.

E-commerce and freight forwarders hit

The abolition of Regime 42 would have ripple effects across several sectors:

• E-commerce brands shipping directly to EU customers under DDP (Delivered Duty Paid) terms.

• 3PL and fulfilment providers using France as a hub for EU-wide distribution.

• B2B exporters routing bulk shipments into France for re-dispatch across Europe.

• Freight forwarders and customs brokers managing imports for global clients.

France’s geographic and logistical advantages have made it one of the most popular entry points into the EU. Any end of Regime 42 could push companies to consider alternative hubs such as the Netherlands or Belgium, where VAT rules may still offer cash flow benefits.