UK exporters using Delivery Duty Paid (DDP) shipments to the EU will face stricter compliance requirements from 1 January, particularly for goods routed through France, following changes confirmed by French tax authorities.
Under the new rules, exporters will no longer be able to ship goods into the EU under DDP terms unless the importer of record is established in the EU. In practice, this means that UK-based companies must either hold a French VAT number or ensure that an EU-established entity acts as the importer of record for shipments entering via France.
Importer-of-record responsibility under scrutiny
The change targets the importer-of-record arrangements commonly used in DDP shipments, where UK exporters have continued to assume responsibility for customs clearance and VAT despite being established outside the EU.
French authorities have clarified that this approach will no longer be accepted. Without an EU establishment or French VAT registration, UK exporters risk customs clearance issues, delays, or refusal of entry for affected shipments.
The tightening of enforcement is expected to have a particular impact on UK–EU flows transiting through France, even where the final delivery destination is another EU member state.
Increased uncertainty for exporters and hauliers
The clarification has created uncertainty among exporters and logistics providers, especially those relying on DDP to offer door-to-door delivery to EU customers. For hauliers and freight forwarders, the changes increase the risk of border disruption if importer-of-record responsibilities are not correctly structured before shipment.
From an operational perspective, the rules shift the focus from contractual Incoterms to legal and tax establishment, an area that many smaller exporters may not have addressed since Brexit.
Market response to the regulatory change
In response to the tightening French requirements, logistics providers have begun adjusting their customs offerings. Europa Worldwide Group, for example, has introduced two additional DDP handling options aimed at addressing importer-of-record and VAT compliance issues linked to France.
According to Europa, the services allow exporters either to ship under DDP using an EU-based importer of record, or to operate using a French VAT registration where applicable. The company says the solutions are integrated with UK and French customs systems.
Europa confirmed that it has been working with customers affected by the change, including UK exporters shipping via France, to restructure their DDP arrangements ahead of the January deadline.
What operators should check now
For hauliers, freight forwarders and exporters, the key issue is not the service provider, but whether their current DDP flows comply with the French interpretation of importer-of-record rules.
Operators should verify:
- who is acting as importer of record on DDP shipments,
- whether that entity is established in the EU,
- and whether a valid French VAT registration is required for goods entering via France.
With enforcement expected from the start of the year, shipments that do not meet the new requirements may face customs delays or rejection, adding further pressure to already complex UK–EU trade flows.
