Smart Border France: Regimes 40 and 42 for UK Exporters

For British exporters, France’s Smart Border is a customs operating system for Channel freight, not a promise of a border without controls. It links declarations, vehicles and routing decisions before a lorry reaches the crossing. Since 20 April 2026, the Obligatory Logistics Envelope (ELO) has added a single barcode reference for each transport unit. The commercial question is now less about whether formalities exist and more about who prepares them, who imports the goods and where Value Added Tax (VAT) is accounted for.

Smart Border for UK exporters: what changes at the French border

The Smart Border uses advance customs data, vehicle identification and automated routing.
One ELO is required for each transport unit using the French system.
Regime 40 generally releases goods for free circulation and home use in France.
Regime 42 may replace transit when goods enter through France and immediately continue to another European Union (EU) member state.
The right model depends on the importer, destination, VAT position, goods and data quality.

What is the Smart Border?

French Customs introduced the Smart Border when customs controls returned to UK-EU trade.

Its design rests on three steps:

declarations are completed before arrival
the declaration barcode is paired with the means of transport
crossing notifications are sent automatically to the declarant.

This allows controls to be targeted while compliant loads continue through the Channel route.

The ELO now groups the references and formalities connected with a transport unit under one barcode. It must be created before the crossing by a designated person within the logistics chain. The driver presents this barcode during check-in so that the ferry or shuttle operator can associate the vehicle with its customs movements.

This makes data coordination before departure a central part of the shipment. A carrier arriving on time cannot compensate for an incorrect declaration reference, a missing VAT number or an inconsistency between the invoice and the goods loaded.

🔎 Discover what you should know about doing your VAT registration in France

James Barker, UK Carrier Manager and a service-provider expert in the UK Business Centre Lille network, describes the expected commercial result in direct terms. Smart Border is, he says, “the quickest and most seamless way to get the goods to your EU customers”.

That statement reflects the purpose of the system from the exporter’s perspective. The ability to deliver without avoidable administrative stops still depends on accurate declarations, a valid VAT model and correctly matched logistics data.

ENS and ICS2: the safety and security layer

Customs clearance is only one part of the preparation. Goods entering or transiting through the EU must also be covered by an Entry Summary Declaration (ENS) containing advance safety and security data. This information is submitted through the EU’s Import Control System 2 (ICS2) before arrival and is used by customs authorities for risk analysis.

ICS2 has been fully operational for the relevant French road and rail flows since 1 January 2026. For goods using the UK-France Smart Border, the ENS therefore needs to be prepared alongside the other customs and logistics references before the crossing. French Customs has specifically integrated ICS2 requirements into the Smart Border and ELO process.

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What is the difference between Regime 40 and Regime 42 for UK exporters?

Regimes 40 and 42 are two routes that UK exporters may use when importing goods through France. These regimes are not separate components of the Smart Border. The Smart Border manages the crossing and customs data, while the selected customs regime determines how the goods are imported and how VAT is treated.

The choice depends on the importer, the final destination and the company’s VAT arrangements.

Regime 40: importing goods into France

Regime 40 is generally used when goods are released for free circulation and consumption in France. A UK exporter selling under Delivered Duty Paid (DDP) terms may organise the import itself, which can require French VAT identification and support from customs and tax specialists.

Import VAT is reported through the French VAT return by businesses identified for VAT in France. This avoids paying import VAT through the customs declaration, but it does not remove the company’s reporting obligations.

For UK exporters, the main decision is whether they are ready to take responsibility for the import process. The importer, customs declaration, VAT registration, invoice and delivery terms must all be consistent.

Regime 42: entering France before delivery elsewhere in the EU

Regime 42 may apply when goods enter the EU through France and are then delivered immediately to a customer in another member state. Customs duties are dealt with at the French entry point, while import VAT may be exempted in France when the required conditions are met.

The regime can also offer an alternative to customs transit.

“This also takes away the need for your hauliers to use transit documents and to have to report to customs offices in mainland Europe.” – James Barker

The goods can continue from France to their EU destination without a separate transit movement. The destination customer still accounts for the intra-Community acquisition under the applicable VAT rules.

Regime 42 requires accurate VAT numbers, evidence of onward transport and a clear link between the import and the subsequent EU supply. Customs and VAT specialists should confirm whether the model fits the transaction.

DDP or DAP: who handles the import?

Regimes 40 and 42 describe customs treatment, but UK exporters also need to decide who will take responsibility for the import. This is where the choice between Delivered Duty Paid (DDP) and Delivered at Place (DAP) becomes important.

Under DDP, the UK seller is responsible for import clearance and the associated duties and formalities before delivering the goods to the customer. Under DAP, the seller still arranges transport to the agreed destination, but the EU buyer is responsible for import clearance, duties and taxes.

DAP can therefore be a practical alternative when the European customer is willing and able to act as importer. DDP offers the customer a more integrated delivery experience but places more customs and tax responsibilities on the UK exporter. The right choice depends on the commercial agreement, VAT position and capabilities of each party.

Smart Border: 7 questions UK exporters should ask themselves

The Smart Border can automate routing, but it cannot repair a weak transaction. Before collection, the parties need a common answer to six questions:

Who is the importer of record?

Are the goods imported into France or immediately supplied to another member state?

Which VAT numbers and representation arrangements are required?

Who creates the customs declaration and ELO?

Who gives the driver the correct references?

ENS and ELO: Who provides the safety and security data, creates the required references and sends them to the carrier?

Who monitors release and resolves a data mismatch?

A missing commodity code, inconsistent invoice, incorrect vehicle pairing or unclear importer can interrupt the crossing even when the transport is on time. Exporters should map the information flow from sales order to customs declaration, carrier check-in, French release and customer delivery.

What BBL Group’s expertise adds within the UKBC Lille network

BBL Group combines road and overseas transport, customs management and contract logistics. Its customs network includes more than 120 declarants, centralised clearance through Lille and coverage of 27 French entry points.

This joined-up expertise matters because Smart Border operations depend on consistent information across the full logistics chain. Customs declarations, VAT arrangements, carrier instructions and delivery data must all match before the goods reach the border.

BBL can help exporters assess whether Regime 40, Regime 42, transit or another customs route fits their sales and distribution model. Within the UKBC Lille network, the company is one of the specialist partners that British businesses may be connected with when they need customs and logistics expertise for Cross-Channel trade.

🔎 Learn more about the benefit of having a customs agent like BBL at the border for your exports

How the UK Business Centre Lille can help UK exporters

Search results often mix two subjects. The French Smart Border discussed here concerns customs and freight between the UK and France. The European Commission’s “Smart Borders” programme concerns travellers at the external Schengen border, including the Entry/Exit System (EES) and the future European Travel Information and Authorisation System (ETIAS). The shared vocabulary should not lead businesses to combine passenger rules with freight procedures.

How the UK Business Centre Lille can help UK exporters

The UK Business Centre Lille gives British companies a single point of contact for their questions about entering and operating in France and the European Union. The team first looks at the company’s business model, goods flows, target markets and operational challenges to identify which expertise is needed.

As a network, UKBC Lille then connects the company with the right English-speaking public and private experts. For a Smart Border project, this may include specialists in customs, VAT, transport and logistics. The aim is to turn a broad market-entry question into a clear brief and a series of qualified introductions.

British companies can express their needs to discuss their project and access the relevant Cross-Channel expertise.

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Key takeways on the Smart Border for UK exporters

France’s Smart Border can reduce avoidable stops by linking advance declarations, vehicle identification and customs routing. Regimes 40 and 42 can support smoother deliveries, but they create different responsibilities for the exporter, importer and EU customer. The strongest model is the one validated against the real flow of goods, contracts and VAT obligations.

UK companies should define the importer, destination and tax route before offering DDP or booking the carrier. The UKBC Lille can help them express that need and get connected with the right Cross-Channel experts.

FAQ on the Smart Border

Is Smart Border a customs regime?

No. It is the information and border-management system used for Channel freight. Regimes 40 and 42 are customs procedure codes used within an import model.

Does regime 42 remove all VAT obligations?

No. It can exempt import VAT in France when the conditions are met, but the destination customer normally accounts for VAT on the intra-Community acquisition.

Does every truck need an ELO?

French Customs requires one ELO for each transport unit using the Smart Border from 20 April 2026.

Can every UK exporter use DDP with regime 40 or 42?

No. Suitability depends on the goods, importer, destination, VAT registrations, customer status and contract. A customs and VAT specialist should validate the route.