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Plan now to avoid delays after Regime 42 changes, urges forwarder

[ September 23, 2025   //   ]

Coming changes to the law that will prevent non-EU companies from using limited tax representation in France under Customs Regime 42 should not stop UK businesses from trading, says Baxter Freight associate director for customs and compliance, Chris Roome.
However, for UK businesses moving goods into the EU under Delivered Duty Paid (DDP) terms – particularly those clearing shipments at the smart border – the change could have significant consequences, he adds.
He says: “This is a different way of thinking, and shouldn’t stop any UK business trading with the EU. The official document was released in 2024 with an original start date of January 2025, later postponed to 2026. It’s about French authorities tightening VAT controls and aligning with other EU countries.
“I don’t believe this will undermine UK-France trade relations, and other steps are being taken to make trade easier. This change is about ensuring duty is paid correctly, and on closing VAT loopholes.”
He adds: “For customers wanting to use a DDP solution, it adds an extra level of complexity. Ad-hoc consignments become more cumbersome due to the need to set up the EU buyer or obtain a French VAT number, which requires a tax representative. There are ways around this, but it’s key that customers fully understand their options – and my team can help simplify these processes.
“All UK companies exporting via R42 DDP will be affected, but particularly those sending fewer pallets, groupage consignments, or lower-value shipments. Transactional businesses may find the ongoing VAT management fees less cost-effective, so exploring all options will be essential.”
He adds that many UK companies may need to set up the EU consignee as the importer of record, which requires a direct representation form. However, not everyone understands this and some refuse to complete the documentation. The alternative is setting up R40 with a French VAT number, which involves monthly management fees and potential delays if companies don’t apply early. It currently takes around six weeks to obtain a VAT number.
He urges companies impacted to speak with Baxter Freight about available solutions to avoid fines or delays in 2026.

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