France will phase out the occasional tax representative regime on December 31, 2025, as part of an effort to harmonize VAT and customs compliance across the EU. From January 1, 2026, companies established outside the European Union will no longer be allowed to import under Customs Regime 42 using the VAT number of a simplified representative.

Key Implications

Non-EU importers will be required to:

• Obtain their own French VAT registration;

• Declare transactions via an accredited fiscal representative;

• Review and adapt internal procedures for customs declarations, accounting, and logistics.

Note: the permanent fiscal representative framework does not replace the discontinued occasional regime.

Businesses Affected

The reform primarily impacts:

• Non-EU companies importing goods under VAT-exempt Customs Regime 42;

• Businesses that have historically relied on simplified tax representation to streamline VAT and customs duties;

• International groups with supply chains routed through France.

Compliance Risks

Failure to comply with the new requirements may lead to:

• Customs clearance delays or blocked shipments;

• Loss of VAT exemption eligibility;

• Administrative penalties or tax reassessments for non-compliance.

Steps to Ensure Readiness

1. Map import flows currently covered by regime 42.

2. Initiate VAT registration in France before year-end 2025.

3. Update customs and accounting protocols accordingly.

4. Train internal and external partners (accountants, freight forwarders, logistics providers).

5. Allow for processing time — applications to the French tax authorities may take several weeks.

This transition marks a structural change in France’s VAT landscape. Acting early will safeguard operational continuity and ensure full compliance with the upcoming regulations.