Export Knowhow
End of ad hoc tax representation in France: EU clearance
Nov 4, 2025
As a reminder, customs procedure 42 – or EU clearance – allows goods from outside the EU to be imported into a Member State exempt from VAT and their further transport to be then considered an exempt intra-Community supply. As of January 1, 2025, France has put an end to the use of ad hoc tax representation for imports under procedure 42. This change has a direct impact on companies not located in the European Union, such as Swiss firms, which previously used this mechanism to import goods VAT-free via France.
What’s changed:
Specifically, non-EU companies, such as Swiss firms, can no longer appoint an ad hoc tax representative to carry out VAT-free imports into France. France now requires the following:
- full VAT registration in France;
- the appointment of an accredited tax representative, authorized to fulfill all reporting obligations.
This change is part of a desire to strengthen tax controls and align French practices with those of other Member States.
What’s still allowed:
Procedure 42 remains applicable in France. It still allows VAT-free imports if the goods are subsequently shipped to another EU country. But only companies
- already registered for VAT in France,
or
- located in an EU Member State can benefit from it without additional constraints.
For Swiss companies (and other non-EU countries)
Swiss companies can continue to import goods VAT-free into the European Union via EU clearance, provided they comply with the new French regulations. In France, this means:
- VAT registration;
- appointment of an accredited tax representative.
Alternatively, Swiss companies can choose to complete their EU clearance in another Member State, such as Germany, Austria or Italy, where ad-hoc tax representation is still accepted. Goods can then be freely delivered within the EU, including France, subject to intra-Community supply rules.
The French tax authorities have announced an extension of the “ad hoc" tax representation period until December 31, 2025. This measure is intended to give companies based outside the EU more time to adapt, particularly by setting up an import mandate or completing VAT registration formalities. VAT numbers assigned to one-time tax representatives will remain valid until this date.
Source: RES - Taxe sur la valeur ajoutée | bofip.impots.gouv.fr
