REGIME 42 at the EU Frontier: Fast Customs Clearance via Calais or Dunkirk
Move freight across the Channel and two things hit your margin: import VAT and time at the border. REGIME 42—release for free circulation with an onward intra‑EU supply—sits in the middle of both. If you route via the SMART border at Calais or Dunkirk, the rules, the tech, and the timing matter.
What REGIME 42 actually does
In plain English, Procedure/Regime 42 lets you import into one EU country (for example, France) without paying import VAT at the frontier when the goods immediately ship to a customer in another EU member state. You account for VAT in the destination country instead. HMRC defines it as “release for free circulation with simultaneous VAT‑exempt onward supply to another member state.”
The frontier is getting smarter (and stricter)
France’s SMART border links your customs MRNs to the vehicle registration and checks everything as HGVs board and arrive. The Port of Calais puts it plainly: “Pairing is the computer reconciliation between the MRN and the vehicle registration (number plate).” https://www.portboulognecalais.fr/en/freight-import-export French Customs sums it up as anticipation, identification, and automation. https://www.portboulognecalais.fr/en/the-smarter-border
ELO: one barcode to rule your documents
In 2025, France introduced ELO (Enveloppe Logistique Obligatoire)—a single digital “envelope” that groups customs and safety documents under one barcode. French Customs confirms: “There will be a five‑month transitional period ending on 1 September 2025, after which ELO will become mandatory… ELO will exist in parallel with the smart border system.”
What changes in 2026 (and what doesn’t)
France is not abolishing REGIME 42. What changes from 31 December 2025 is the end of “one‑off fiscal representation,” often used with 42. Non‑EU businesses will need to register for VAT in France for arrangements like DDP. A number of French customs specialists also clarify the rumour: the regime itself continues.
Practical steps to run 42 cleanly at Calais/Dunkirk
- Prove onward movement. Keep the invoice, CMR, and delivery evidence that ties back to the declaration and the ELO barcode.
- Match data perfectly. Plate, MRNs, ferry booking—ELO pairs these; mismatches trigger stops.
- Name the right importer. Use the correct EU VAT number and destination details.
- Sync safety filings. ICS2 entry summary declarations (ENS) need to align with what’s in your envelope. Why the ports matter: scale and discipline
Scale brings stable processes—and little patience for errors. In 2024, Calais handled about 1.8 million freight units.
Where Zelir Ltd helps
You handle sales. Zelir handles the border. If you need a partner to prepare declarations, build the ELO envelope, and keep REGIME 42 compliant during and after the 2025–26 transition, the team can help:
- What is Customs Clearance?
- Customs Declaration Services
- Import Declaration Services
- ENS & Safety and Security Declaration Services
- Import Control System 2 (ICS2) Services
- Dover Customs Clearance
FAQs
What documents prove my onward EU supply under 42?
Invoice with your EU customer, CMR, and delivery evidence that match the declaration and the ELO barcode.
Do I still use the Smart Border with ELO?
Yes. ELO works alongside the Smart Border and uses one barcode to group your files. https://www.douane.gouv.fr/actualites/implementation-elo-obligatory-logistics-envelope-calendar-scope-and-operator-guides
Is REGIME 42 still available at Calais or Dunkirk in 2025?
Yes. The representation rules change at the end of 2025; the regime itself continues. https://www.asd-int.com/en/end-of-one-off-fiscal-representation-regime-42-on-31-12-2025-what-non-european-businesses-need-to-know/
Why did my trailer get stopped even with MRNs?
Pairing failed. Plate, manifest, and MRNs didn’t match the ELO envelope, or an ENS detail conflicted. Fix the data, then retry. https://www.portboulognecalais.fr/en/freight-import-export
Does traffic volume affect delays?
Busy ports inspect faster and expect clean data. Calais handled ~1.8m units; Dunkirk 493k. (Calais: https://ferryshippingnews.com/2024-port-boulogne-calais-maintains-its-momentum/; Dunkirk: https://www.dunkerque-port.fr/wp-content/uploads/2025/01/Press_Kit_2025.pdf)