Shipping DDP into the EU? Here’s What You Need to Know About the End of Regime 42

From 1 January 2026, major changes are coming to how UK exporters can deliver goods DDP (Delivered Duty Paid) into the EU — especially if you currently import via France using Regime 42 (Customs Procedure Code 4200).

If you’re one of the many UK businesses that’s been using this route to keep things simple for your EU customers, now’s the time to prepare.

This guide explains what’s changing, why it matters, and what practical steps you can take to stay compliant and keep your goods moving smoothly.

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What Is Regime 42 (CPC 4200)?

Regime 42, or Customs Procedure Code 4200, is an EU customs simplification that allows goods to be imported into one EU country (for example, France) and then dispatched to another EU Member State without paying import VAT at the border.

Instead, the VAT is accounted for at the destination country — meaning the importer avoids double taxation and simplifies cross-border trade inside the EU.

Before Brexit, UK exporters could use this procedure easily.
After Brexit, non-EU exporters (like those in the UK) found a workaround:

👉 Regime 42 + DDP + limited tax representation

This combination allowed UK exporters to keep offering DDP deliveries — “door-to-door” with no extra costs for EU customers — without registering for VAT in France.
The limited tax representative (a fiscal agent) used their own “global VAT number” to handle the import.

This made life much easier for UK exporters who wanted to keep trading like they did pre-Brexit.

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What’s Changing from 1 January 2026

From 1 January 2026, France will end the use of limited tax representation for non-EU businesses importing via French ports, airports, and logistics hubs.

That means:

• Non-EU exporters (including UK businesses) can no longer use a fiscal rep’s global VAT number for imports.
  
• You’ll no longer be able to import under CPC 4200 as the seller unless you have your own VAT registration.
  
• To keep shipping DDP, you’ll need to register for French VAT and file local VAT returns.
  

This change is being made to:

• Harmonise VAT compliance across the EU
  
• Improve transparency and prevent fraud
  
• Ensure fair competition between EU and non-EU businesses
  

It’s worth noting that this isn’t a customs change — CPC 4200 itself isn’t being abolished.
It’s a fiscal change — meaning it affects VAT responsibility and reporting, not customs clearance steps.

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Your Options Moving Forward

The changes don’t mean you have to stop selling DDP. But they do mean you’ll need to update how you handle VAT and customs in France.

Option 1 – Register for French VAT (and a linked EORI)

If you want to keep delivering DDP, this is the only compliant way to do it.

• Apply for a French VAT number (takes around 3–5 weeks).
  
• Apply for a French EORI number (issued once you have a VAT number).
  
• Import your goods under CPC 4000 (Regime 40) instead of 4200.
  
• You’ll be the importer of record in France.
  
• Import VAT can be deferred through your VAT return (no upfront cashflow hit).
  
• You’ll file periodic VAT returns in France to stay compliant.
  

You can handle this directly, or work with a fiscal representative who manages filings and local communication on your behalf — but the VAT registration will still be in your company’s name.

💡 Good to know: Having a French VAT number doesn’t mean setting up a French company. It’s purely a tax registration — you’ll remain a UK-based business.

Option 2 – Switch to DAP or Another Incoterm

If you’d rather not register for VAT, you can change the delivery terms.

• Under DAP (Delivered at Place), your EU customer becomes the importer of record.
  
• They pay import VAT and any customs duties directly.
  
• You avoid EU VAT and EORI registration.
  
• However, this shifts responsibility and admin to your buyer — something your EU customers might resist.
  

If you sell to multiple EU customers, it’s a good idea to discuss Incoterm changes early and make sure everyone understands what’s changing from January 2026.

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Can You Still Use Regime 42?

Not as a UK exporter under DDP. From 2026, only the EU buyer or their appointed representative can act as the importer under Regime 42 — not the UK seller.

You can, however:

• Continue using Regime 42 for DAP shipments, where your EU buyer is the importer.
  

Or move to Regime 40 (CPC 4000) if you register for French VAT and act as importer yourself.

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Why Acting Early Matters

Applying for French VAT and EORI can currently take 3–5 weeks, but that’s expected to increase as more exporters rush to apply before the deadline.

If you want to maintain DDP shipments without disruption, it’s best to:

1. Start the VAT registration process asap.
   
2. Talk to your customs broker or freight forwarder about changing CPC codes from 4200 to 4000.
   
3. Review your Incoterms and contracts with EU buyers.
   
4. Set up VAT return and reporting systems in advance.
   

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Useful Resources and Partners

Here are some organisations that can help with VAT registration, representation, or compliance:

VAT & Fiscal Representation

• Avalara – EU VAT registration and fiscal representation
  
• SimplyVAT.com – UK-based specialists in EU VAT compliance
  
• ASD Group – French fiscal representation service
  
• MHA or Menzies LLP – UK accounting firms with EU VAT expertise
  

Logistics & Customs Coordination

• Your freight forwarder or customs broker can advise on using CPC 4000 and aligning clearance processes.
  

You’ll also need to update any direct or indirect representation forms used with your brokers.

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How Exporter Services Can Help

We’re here to make sure your business is ready.
Our team can:

• Explain your options clearly — whether to maintain DDP or move to DAP.
  
• Coordinate with your customs agents to update your CPC procedures.
  
• Review your documentation to ensure smooth clearance after the rule change.
  

If you’d like guidance on what this means for your company, just get in touch — we’ll help you plan the best route forward.

Why not join our 90-minute training course: Preparing for changes to Regime 42? Please note that spaces are limited and are filling quickly.

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Summary

DDP under CPC 4200 + limited tax rep	DDP under CPC 4000 with your own VAT & EORI
Fiscal rep’s global VAT number used	Must have your own French VAT registration
No regular VAT filing	Must file VAT returns in France
No EORI in France	Need a French (EU) EORI

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FAQs