New regulations for using Regime 42 via France

From 1st January 2026, significant legislative changes will come into effect for UK-based exporters currently using Customs Procedure 42 (commonly known as Regime 42).

UK exporters wishing to continue using Regime 42 will face new compliance obligations.

Currently, UK businesses can appoint freight forwarders, such as DSV or customs representatives, to act on their behalf as fiscal representatives for Regime 42 imports into the EU via France. This arrangement enables fiscal representatives to use their own French VAT numbers for customs declarations, allowing non-EU companies to avoid the administrative burden of obtaining a French VAT registration.

This will not be possible from January 2026.

DSV has the solutions which will help your business continue to easily trade with your EU-based customers.

Regime 42

Regime 42 will still be possible from 2026.

However, the EU buyer must act as the Importer of Record, with any duty payments billed back to the UK exporter, as is currently the case.

DSV will use the Smart Border clearance process, and your shipment will be in free circulation upon arrival in France with no further customs clearances required.

Main Points for Regime 42:
• Our trusted partner in France can act as the limited tax representative on behalf of the EU buyer using the limited tax representative's Global VAT number 
• A New Power of Attorney and Mandate will be required from the EU buyer
• Duties and taxes will be billed back to the UK exporter
• The terms of delivery must be stated as DAP

Regime 40

As an alternative to the process where the EU buyer must act as the Importer of Record, DSV can offer to clear cargo under Customs Regime 40.

The key benefit of Regime 40 is that it enables goods to be cleared in France and delivered to any EU country without the requirement for a VAT number in the country of final delivery.

Main Points for Regime 40:
• A French VAT number and an EU EORI number will need to be obtained by the UK exporter
• The UK exporter will act as the Importer of Record using their French VAT number
• VAT payments can be deferred on your French VAT return. This makes the process tax neutral and protects cash flow by avoiding upfront payments
• The UK exporter is responsible for filing the VAT accounting. DSV’s tax specialist partner in France can be appointed to facilitate your VAT filing and support with any questions you may have

DSV can support you in obtaining a French VAT number and an EU EORI number through our partner in France. The process typically takes 3–5 weeks from application to receipt of the VAT number.

Obtaining a French VAT number will enable you to continue clearing goods and delivering to the final destination under DDP terms, both in France and across other EU Member States. Once the goods are cleared in France using your French VAT number, they can be sold and delivered on a DDP basis anywhere within the EU.

As with Regime 42, DSV will use the Smart Border clearance process, ensuring your shipment is in free circulation upon arrival in France, with no further customs clearances required.

Should you need further information or have questions, please reach out to your contact at DSV Road UK.