Blog | IFGlobal

What the end of Regime 42 means for UK brands and how IFGlobal can help you navigate it

Written by Ryan Grimshaw | Jan 2, 2026

On 1st January 2026, France abolished the simplified VAT import mechanism known as Regime 42, a move with significant implications for UK businesses using France as a gateway into the EU.

In this article, we explain what’s changing, why it matters for your supply chain, and how our solutions can support your continued cross-border growth. 

In this article 

 

 

What Regime 42 was and why it mattered 

Regime 42 (Customs Procedure Code 4200) has historically allowed non-EU companies, including many UK brands, to import goods into France and dispatch them onward to other EU destinations without upfront French VAT or the need for a French VAT registration.  

This worked by appointing a limited fiscal representative in France to handle VAT on the importer’s behalf. For years, Regime 42 offered: 

  • A VAT-neutral way to enter the EU via France 
  • Cash-flow benefits by deferring VAT until the destination state 
  • A streamlined customs entry point that route planners loved 

This made France a popular EU entry gateway for UK exporters and DTC brands selling into the EU. 

 

 

What’s changing in 2026 

From 1st January 2026, France abolished one-off fiscal representation under Regime 42 for non-EU companies. 

  • UK businesses can no longer use a limited fiscal representative’s VAT number to clear goods via Regime 42. 
  • Non-EU importers must register for French VAT in their own name or appoint a full fiscal representative to act on their behalf for VAT and customs reporting. 
  • VAT returns and compliance obligations must be managed directly, or through partners, rather than via a temporary representative. 

In short, the simplified path has ended, and a more robust compliance framework is now the norm. 

 

 

Who will be affected and how 

This change primarily affects UK brands that have historically moved their own inventory cross-border from the UK into the EU. For our clients, this has involved storing stock at our Bocholt facility to support EU order fulfilment.

By localising inventory within the EU, these brands have benefited from the free movement of goods across member states, faster delivery times, and reduced fulfilment costs through access to lower intra-EU courier rates.

Additionally, this change impacts brands that have used Regime 42 under Delivered Duty Paid (DDP) terms via France to another EU country to fulfil B2B orders.


 

Practical compliance options post-Regime 42  

The end of Regime 42 is creating operational friction for UK brands shipping goods into the EU, but it doesn’t have to.  

At IFGlobal, we’ve spent the past year preparing a compliance-lite pathway designed specifically for UK businesses distributing from our Bocholt fulfilment centre. While there are multiple import structures you could adopt, only one genuinely keeps friction low, avoids unnecessary tax exposure, and protects operational agility. 

Below is how each option stacks up, and why Option 1 is the route we lead with for customers using our Bocholt facility.

Option 1. 

Low-compliance import model – Limited Fiscal Representation via Netherlands (recommended) 

This is the simplest, cleanest and lowest-compliance approach, and the model we recommend for the majority of clients. Under this framework: 

  • Goods are imported via the Netherlands under a compliant structure which involves one of our trusted partners acting in the capacity of Limited Fiscal Representative on your behalf. 
  • The import framework is designed to minimise administrative touchpoints, reduce VAT exposure, and maintain operational fluidity. 
  • Stock is then stored and distributed from our Bocholt fulfilment centre for EU-wide delivery. 
  • You maintain full ownership of your goods without taking on unnecessary regulatory obligations.
     

Option 2.

Shipping DAP from the UK (not suitable) 

Shipping under DAP terms from the UK to Bocholt is not workable for inbound stock movements into the fulfilment centre. This option introduces clearance failures, unpredictable duties at the border, and operational delays, and is therefore not compatible with our clients’ needs. 

Option 3.

UK business registers for French VAT 

Registering for VAT in France can technically work, however, it comes with a heavy compliance load. Monthly or quarterly submissions, local representation requirements, ongoing returns, and audit risk all make this route increasingly burdensome over time.  

While our team at IFGlobal can support the logistics, we do not recommend this as the primary structure for Regime 42 replacement due to the escalating cost and admin associated with this option. 

Option 4. 

Consignee becomes the Importer of Record (IOR) 

This option is not viable for UK brands moving inventory into our Bocholt facility. It places the import burden on the consignee, which is incompatible with inbound stock movements where the consignee is not the end customer. We do not recommend this solution. 

Option 5.

UK business creates a Permanent Establishment (PE) in the EU 

Forming an EU presence sounds like a clean solution until you factor in corporate taxation, local accounting obligations and the administration overhead of creating and maintaining a foreign entity. 

In most cases, this option becomes the most expensive and operationally heavy path. We present it for transparency, but it’s rarely suitable for scaling ecommerce brands. 

This model is specifically architected to give UK brands a compliance-lite re-entry path into Europe following the removal of Regime 42, without compromising speed, cost efficiency or customer experience. 

 

 

How IFGlobal makes this easy for international growth 

Choosing the right import structure is only part of the picture. At IFGlobal, we support your entire EU expansion strategy. 

  • Bocholt fulfilment centre (Germany) 
    European storage, pick/pack, and distribution for DTC and B2B. 
     
  • Integrated compliance partners 
    For low-compliance import solutions that eliminate the Regime 42 gap. 
     
  • Cross-border carrier network 
    Fully optimised for EU-wide delivery speeds and cost efficiency. 
     
  • Operational continuity 
    No interruptions, no unnecessary filings, no barriers to scale.