Key Changes to Regime 42: Essential Guidance for UK Seafood Exporters

As of January 1, 2026, significant modifications to Regime 42 will impact UK seafood exporters. Regulatory Affairs Advisor Mat Noakes provides vital insights into these changes and what they mean for businesses operating in the seafood sector.

Understanding the Changes and Their Impact

France’s upcoming changes to Regime 42 (Customs Procedure Code 4200) will reshape how UK exporters manage the entry of goods into the EU. Currently, many UK businesses leverage a French fiscal representative’s VAT number to facilitate clearance under Regime 42, allowing them to defer VAT when goods are transported to another EU member state.

However, under the new French regulations, this fiscal representation model for non-EU businesses will be eliminated. Regime 42 will remain operational, but it will be restricted to entities established or VAT-registered within the EU. Consequently, UK exporters will no longer have the option to utilize a third-party French VAT number for their customs clearance.

Implications for UK Seafood Exporters

With many UK seafood exporters accustomed to using Delivered Duty Paid (DDP) terms via France and leveraging Regime 42 to bypass upfront VAT registration, the upcoming changes will have the following consequences:

1. Loss of Fiscal Representation

UK exporters relying on French fiscal representatives for clearing their seafood consignments will no longer have that option. From 2026 onwards, only importers who are established in the EU or registered for VAT in France will be eligible to use Regime 42.

2. Requirement for French VAT and EORI Registration

To maintain DDP terms—where the exporter is responsible for customs duties and VAT—businesses must directly register for French VAT and obtain a French EORI number. This requirement may introduce additional administrative burdens and compliance risks for exporters.

3. Amendments to Incoterms

Exporters opting against registering in France will need to revise their Incoterms to Delivered at Place (DAP) or similar. This shift will transfer responsibility for import clearance, VAT, and duties to the EU customer. Under these conditions, Regime 42 could still apply if the buyer meets the qualifications of an importer under EU regulations.

4. Commercial Considerations

Each exporting business will need to evaluate which strategy is most viable. High-volume seafood exporters may find that obtaining French VAT registration is beneficial. In contrast, smaller or infrequent exporters might consider altering their delivery terms to alleviate administrative challenges.

Conclusion

While Regime 42 will continue to exist, the methods UK exporters use to access it are undergoing significant changes as of January 2026. It is essential for UK seafood exporters to either register for VAT in France or adjust their trading terms proactively to ensure seamless supply and compliance with EU customs regulations.

It is strongly recommended to consult with a customs agent or freight forwarder regarding the forthcoming adjustments to the use of Regime 42.

Source

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