Regime 42 Changes – What Exporters Need to Know from 1st January 2026

Updated: 29th October 2025

From 1st January 2026, new rules will come into effect regarding Regime 42 for exporters shipping goods from Great Britain into the EU.

Until now, many UK exporters have been able to ship under DDP (Delivered Duty Paid) terms using Regime 42 without holding an EU VAT and EORI number, relying instead on an agent’s fiscal representation. However, this approach has become linked to significant fraud cases across Europe, leading to new compliance measures being introduced.

What’s Changing

From January, Regime 42 can no longer be used under DDP terms unless the exporter holds a French VAT and EORI number. This means fiscal representation under another party’s VAT/EORI will no longer be accepted.

What You Can Do

If you currently export under Regime 42, you’ll need to review your Incoterms and VAT/EORI setup before the new rules take effect.

There are now two main options:

Option 1 – Continue Using a Non-EU VAT & EORI

If you don’t hold an EU VAT or EORI number, you’ll need to switch your Incoterms from DDP to DAP.

• The EU buyer will then become the importer of record, taking responsibility for any VAT or Duty.

• If the goods are being delivered into France and the buyer is French VAT-registered, it will fall under Regime 40.

• If the buyer is based elsewhere in the EU, they must ensure their VAT & EORI are Intra-EU registered to use Regime 42 for clearance through France.

Option 2 – Obtain Your Own EU VAT & EORI

As a GB exporter, you can apply for your own EU VAT and EORI registration:

• If you register in France, you’ll be able to continue shipping on DDP terms using Regime 40.

• Alternatively, if you register for VAT & EORI in another EU country (with Intra-EU registration), you can continue using Regime 42 under DAP terms.

Act Now

Applying for an EU VAT & EORI can take time, so it’s important to start the process early to ensure compliance before 1st January 2026.

HTE Recruitment’s logistics team works closely with exporters and freight operators across the UK, helping companies stay compliant and well-informed about customs and VAT changes. If you’d like to discuss how these Regime 42 changes could affect your shipments, our team are here to help.

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