France's Customs Regime 42 Reform Raises the Compliance Bar for Non-EU Exporters but Leaves the Door Open for Adaptation

France's Customs Procedure Code Regime 42 changes, which took effect on 1 January 2026, have materially affected UK exporters that use France as their entry point into the European Union — particularly those that previously shipped on Delivered Duty Paid (DDP) terms and relied on limited fiscal representation. The changes raise the compliance bar rather than closing off the market entirely, but they demand swift adaptation from businesses that have not yet updated their VAT and logistics arrangements.

Under the previous system, UK exporters could appoint a French limited tax representative — a local partner with a French VAT number — to manage their EU import clearances under Regime 42. This allowed goods to be imported into France, cleared through customs, and then shipped across the EU without the exporter registering for French VAT or acting as the Importer of Record. From 1 January 2026, France no longer allows non-EU businesses to rely on a representative's VAT number to import goods under Regime 42.

As per loadstar, the main challenges are obtaining a French VAT registration and understanding where that puts you in relation to [Importer of Record] and your supply chain. UK exporters shipping DDP can no longer use a fiscal representative's VAT number and must now either register for VAT directly in France — thereby becoming the Importer of Record — or shift import responsibility to their EU buyers. The change also interacts with the EU's mandatory Enveloppe Logistique Obligatoire (ELO) barcode requirement, which became mandatory for all trucks using French Channel crossings from April 20, 2026, requiring every vehicle to present a single ELO barcode at check-in linking all export, import and safety declarations.

Businesses that adapt early are well-positioned to differentiate themselves, deepen customer relationships, and capture opportunities as competitors retreat. However, those that fail to update their setup face the prospect of blocked imports, unexpected VAT liabilities, and the loss of simplified customs access — at a time when European customs reforms are also moving towards centralised data requirements under the EU Customs Data Hub.