France’s VAT Shake-Up: The 2026 Rule Change that will reshape UK–EU exports
At the end of 2025, a quiet but powerful shift will take place in European trade. For thousands of UK exporters, many of whom we at Simarco support daily, France, long a favoured gateway into the EU, is about to change the rules of the game.
From 1 January 2026, the French government will end limited tax representation for non-EU businesses under its Regime 42 customs procedure. The change may sound technical, but as we’ve seen in similar VAT reforms, the operational impact will be anything but small.
For UK businesses currently shipping DDP Regime 42 (Delivered Duty Paid) into Europe via France, this means one thing: it’s time to rethink your VAT and logistics setup.
What’s Changing and Why it Matters?
For years, UK exporters have been able to appoint a French “limited tax representative” (a local partner with a French VAT number) to manage their EU import clearances under Regime 42. This system allowed goods to be imported into France, cleared through customs, and then shipped across the EU without the exporter registering for French VAT, or the EU buyer being the Importer of Record.
It was a win-win arrangement:
- Exporters could offer DDP terms and manage duties and taxes on behalf of their customers.
- EU buyers enjoyed a seamless experience, free from the burden of customs formalities.
From 2026, that bridge disappears. France will no longer allow non-EU businesses to rely on a representative’s VAT number to import goods under Regime 42. Instead, UK exporters will face two main choices if they wish to continue shipping DDP style.
Option 1: Take Control – Register for French VAT
The first path is to register for French VAT and become the Importer of Record (IoR). This option gives exporters full control over customs, VAT, and EU-bound logistics.
With your own VAT registration, you can:
- Import goods directly into France under your company’s name.
- Distribute those goods freely across the EU.
- Hold stock in France for faster redistribution.
- Sell directly to both B2B and B2C customers without involving buyers in import procedures.
While this route involves administrative responsibilities, VAT filings, compliance checks, and setup costs, the benefits are significant for high-volume exporters.
At Simarco, we help clients implement this end-to-end approach, from VAT registration and fiscal representation to bonded warehousing and EU distribution. Our integrated logistics network allows exporters to manage customs, storage, and delivery processes seamlessly through a single provider.
Option 2: Pass the Baton – The Buyer as Importer
For smaller exporters, or those serving a few key EU customers, a second option may prove more practical: shifting import responsibility to the EU buyer.
Under this “buyer-as-importer” model:
- The UK exporter arranges transport and works with a French customs broker.
- The EU buyer becomes the Importer of Record (IoR), granting Power of Attorney (PoA) to the exporter’s broker for clearance.
- Simarco’s fiscal partners use a global VAT number to ensure VAT is deferred to the buyer’s home country, maintaining neutrality.
This model can preserve much of the old DDP experience but requires a willing and VAT-registered buyer comfortable with import liability. For strong, long-term trading relationships, it’s a workable and compliant solution. However, for exporters juggling dozens of EU buyers, it might be a tougher sell.
Choosing the Right Path
Your decision depends largely on scale and frequency:
| Export Profile | Recommended Option | Key Benefits |
| High-volume, multi-EU customer exports | Register for French VAT | Control, consistency, faster EU distribution |
| Low-volume, limited EU customers | Buyer as Importer | Lower admin burden, avoids VAT registration |
Whatever your route, plan early!
- Begin reviewing DDP/DAP terms with EU customers.
- Assess whether VAT registration is commercially viable.
- Start the registration process early — VAT setup can take several weeks, and a surge in late-2025 applications is likely.
Transition Support from Simarco
Our Customs and VAT Specialists are already supporting UK exporters through this transition, offering tailored solutions based on shipment frequency, product type, and buyer setup.
We manage the entire process, from fiscal representation and VAT filings to freight forwarding and EU distribution, ensuring your compliance and continuity under the new regime.
We’re also collaborating with our fiscal partners to offer discounted registration fees for early adopters and hands-on guidance throughout the process.
What’s Next?
France’s decision to end limited tax representation forms part of a broader EU push for VAT transparency and harmonisation. Other member states are likely to follow in the coming years.
For UK exporters, this isn’t just a rule change, it’s a strategic turning point. Companies that act now will gain smoother access to EU markets, stronger compliance credentials, and greater control over their logistics and client relationships.
Mark Wraight, Commercial Operations Director at Simarco, puts it simply: “From 2026, UK exporters can no longer rely on a French partner’s VAT number to move goods duty-paid into the EU. You’ll need to decide whether to:
- Register for French VAT and take full control of your EU trade; or
- Shift import responsibility to your EU buyers with their consent.
Whichever route you choose, the message is clear – review your setup and act now. The sooner you plan, the smoother your transition when France’s VAT reform takes effect.”