Rhenus urges businesses to act now on French VAT changes

Global logistics provider Rhenus is advising UK businesses exporting Delivery Duty Paid (DDP) goods into the EU to prepare for new French VAT rules that will change how the popular Regime 42 import solution can be applied to imports into the EU from 1st January 2026. Regime 42 legislation defers the VAT businesses need to pay at the import stage to the destination EU member state. From January, non-EU companies using Regime 42 will no longer have access to the import procedure when using the services of a limited French tax representative.

Companies should now consider the options available post January 1st, which include:

Registering for a French VAT number
Transferring liability for limited tax representation to an EU business

Failure to adapt to the new regulatory landscape could cause unwanted complexities across DDP supply chains, and for some could mean a return to DAP solutions.

Why businesses must prepare now

The 2026 legislation aims to tighten EU VAT compliance but also introduces uncertainty for businesses. Companies that wait until late 2025 to act risk being unable to account for import VAT, potentially causing supply chain disruption. "Many businesses have been left with the misunderstanding that the new regulation means that Regime 42 is no longer an option for their supply chain, but that's not the case," said Rob Mulligan, UK Customs Manager, Rhenus UK. "In fact, it's the way UK companies access Regime 42 in France that will change."

A key aspect in preparing for the upcoming changes is to understand the new legislation ahead of introduction, Mulligan explained. "Working closely with our French partner, we have analysed the new legislation and its implications in depth. This has enabled us to develop a range of solutions for UK DDP exporters, which we believe will prove as popular and user-friendly as the outgoing Regime 42 solution."

Guidance for affected companies

UK exporters can opt to apply for French VAT registration, enabling businesses to continue supplying EU customers on a DDP basis by clearing their goods into Regime 40. This enables exporters to account for VAT directly with French tax administration using the postponed VAT mechanism. Exporters with a preference for the Regime 42 solution can do so by transferring liability for the intra-EU VAT transfer to an EU business - whether an owned business or one the company is supplying. Rhenus now offers this option in the form of the company's DAP42 solution, alongside its existing Regime 40 offering to UK exporters. Rhenus is already working with customers to implement a range of new solutions to ensure DDP shipment continuity into the EU.

This includes reviewing existing supply chains, securing VAT registrations, and revising fiscal representation arrangements ahead of the January deadline. "Compliance with the new legislation doesn't need to be complicated or protracted - but it does need to start sooner rather than later. And that starts with speaking to exporters, so they can make informed decisions alongside their EU customers," Mulligan concluded. "The deadline may feel far away, but businesses considering an application for VAT registration in particular should appreciate that it's not an overnight process.

The good news is that with early planning, these challenges are entirely manageable."