Summary
Summary
France will no longer offer simplified tax representation for non-EU importers starting January 1, 2026, impacting businesses in the UK, Switzerland, Norway, and other non-EU countries.
Starting from next year, France will abolish the beneficial simplified tax representation provision for non-EU importers. The VAT simplification scheme that allowed non-EU importers to import their products through France only to later ship it to the other EU destination, is counting its last days before being obsolete.
The simplified tax representation permitted non-EU sellers to transit goods through France to EU customers in other Member States, without the necessity to pay import VAT upfront. This change will have a significant impact on sellers in the UK, Switzerland, Norway, and other non-EU countries, where domestic traders are part of the cross-border supply chain.
Timeline
From January 1, 2026, non-EU importers will no longer be able to benefit from the simplified tax representation guaranteed under Customs Procedure 42.
Legal Framework
Background
For years, cross-border suppliers could have used Customs Procedure 42 (CP 42) to import goods into France, clear them under Regime 42, and transport the goods directly to a customer residing in another Member State. The applicability of the CP 42 permitted overseas vendors to “use” France as an EU entry point for their goods, which were then shipped to customers in other countries.
Customs Regime 42 gives many benefits to foreign suppliers. Fewer administrative and compliance burdens are automatically provided. In most of these circumstances, the overseas vendor doesn’t have an obligation to register for French VAT, to submit periodic returns, or to have a tax representative in its full capacity.
Less paperwork, less administration, less compliance investment: permits overseas vendors to benefit from CP 42, which is highly compliant with French laws. However, from January 1, 2026, this will be drastically reduced for non-EU vendors.
End Of Customs Regime 42
From January 1, 2026, France will abolish its long-standing VAT simplification scheme for non-EU importers. This will affect merchants in Switzerland, the UK, Norway, and many other countries. When it comes to EU-established businesses, nothing really changes.
Businesses established in Switzerland, the UK, Norway, and other non-EU countries that import goods into France.
EU-established businesses will continue to operate under the provisions of the EU VAT Directive, specifically within the framework of intra-EU trade. When they need to register for VAT in France, they can handle the registration process and all VAT compliance-related responsibilities on their own.
Key changes under the new tax framework
Non-EU established importers will have at least the following obligations when importing goods through France:
- Registration for French VAT
- Submission of periodic reports
- Acccredited tax representative
- Advance payment of import VAT( unless a specific accounting scheme can be used)
How to stay compliant
If your business is established outside the EU and currently imports through France, the call to action is now. We are here to provide you with customized tax assistance to overcome upcoming VAT challenges in France.
We can assist you with the following:
- VAT Registration in France and full compliance with new requirements
- Submission of VAT returns and remittance when needed
- Review of customs clearance procedures
- Assistance with defining the best import strategies and possible re-routing
Takeaway
From January 1, 2026, non-EU businesses that carry out customs or warehouse clearance, or that import goods followed by an exempt intra-EU supply, should register for VAT, submit periodic declarations, and obtain services from a fiscal representative.
Author: Aleksandar Delic
The vendors established in a non-EU country that doesn’t have a preferential bilateral trade agreement with France and that are affected by the Customs Regime 42 have the option to use import agents only for imports for which VAT is fully deductible.
Indirect Tax Manager – E-Commerce
Frequently Asked Questions
The simplified tax representation allowed non-EU importers to transit goods through France to other EU countries without paying import VAT upfront. This provision will end on January 1, 2026, impacting businesses outside the EU, including those in the UK, Switzerland, and Norway.
CP 42 allowed non-EU sellers to import goods into France, clear them under a simplified regime, and then ship them to other EU countries without registering for VAT in France or submitting periodic returns. This reduced administrative burdens and compliance costs.
From January 1, 2026, non-EU importers will be required to register for French VAT, submit periodic reports, appoint an accredited tax representative, and pay import VAT upfront unless using specific accounting schemes.
No, businesses established in the EU will continue to operate under the EU VAT Directive and will not be affected by the end of simplified tax representation for non-EU importers.
Non-EU countries such as the UK, Switzerland, Norway, and others that rely on shipping goods through France to the EU will be directly affected by this change in tax representation rules.
Non-EU businesses will need to meet additional obligations, including VAT registration in France, regular reporting, appointing a tax representative, and paying import VAT upfront, which will increase compliance costs and administrative work.