EMEBI, DEB, DES: declaring intra-EU trade in 2026

Quick answer. Since 1 January 2022, the former DEB has been split in two: the EMEBI (the customs monthly statistical survey, triggered by notification, with no threshold) and the EU sales list for VAT (a tax obligation, from the first euro). The DES separately covers services and is filed no later than the 10th working day of the following month.

Selling goods to a German customer or invoicing a service to a Belgian company triggers reporting obligations that many directors still confuse. The reason is simple: the well-known goods trade declaration (DEB) no longer exists as a single form. It has been replaced by two distinct mechanisms, one statistical and one fiscal, while the European services declaration (DES) stands apart. Understanding this architecture avoids needless filings, omissions and corrections.

At Hayot Expertise, a firm registered with the Ordre des experts-comptables of Ile-de-France, we support French companies and subsidiaries of foreign groups whose intra-EU flows are daily. This article separates EMEBI, the EU sales list and the DES, with thresholds, frequency and the mistakes we see most often.

Until 31 December 2021, the DEB combined in a single form a statistical function (measuring flows of goods) and a tax function (tracking VAT on intra-EU supplies). Since 1 January 2022, customs has separated these two functions.

The EMEBI (monthly statistical survey on intra-EU trade in goods) takes over the statistical part. The EU sales list for VAT takes over the tax part. This distinction is decisive because the two obligations have neither the same trigger nor the same scope. You can owe the EU sales list without being concerned by the EMEBI, and vice versa.

The DES has not changed: it covers services supplied to a taxable customer in another Member State, with its own logic. For the services side, our article on intra-EU VAT on services details the reverse-charge mechanism.

EMEBI: a survey by notification, not a threshold#

This is the point that surprises the most. The EMEBI is not triggered by a turnover amount. The EUR 460,000 threshold often cited is not the criterion in 2026. The EMEBI relies on a sample of businesses selected each year by the administration.

A business owes the EMEBI only if it has received an official notification from customs, usually in December of the previous year. Without that letter, you are exempt from the EMEBI. If you are notified, the return is monthly and a nil return is still mandatory for months with no flow.

The EU sales list for VAT is a tax obligation that tracks intra-EU supplies of goods. The rule is clear: intra-EU supplies of goods must be declared from the first euro. There is no minimum threshold.

It concerns any individual or legal entity dispatching goods to other Member States and identified for VAT, or which has appointed a fiscal representative in France when established outside the EU. The frequency is monthly, with one statement per reference month and per filing account.

Filing runs from the 1st to no later than the 10th working day of the month following the reference month. For a January 2026 flow, the window runs from 1 to 12 February 2026. Partial pre-filling from EMEBI answers is possible, only for so-called code 21 operations. For the detailed obligations and deadlines, see our note on the obligations and deadlines of the EU sales list.

The DES (European services declaration) covers services that give rise to reverse charge of VAT by the taxable customer identified in another Member State. The basis is article 196 of Directive 2006/112/EC, transposed in France into article 259-1 of the CGI, the recapitulative statement itself stemming from article 289 B of the CGI.

The DES is mandatory from the first euro invoiced, as a monthly statement. Filing takes place no later than the 10th working day of the month following the month of VAT chargeability, the same deadline as the EU sales list under the customs calendar. A business under the VAT franchise (articles 293 B and 293 B bis of the CGI) may file the DES on a paper form matching the customs model.

A B2B service supplied to a customer established outside the EU (a US client, for example) is deemed located outside France: it does not give rise to a DES, which only covers the Union. Since 1 January 2021, the United Kingdom is a third country: services to the UK do not fall within the DES. Exporting freelancers will find the full framework in our guide on freelance status and VAT in France.

Here is the sequence we apply in files with recurring intra-EU flows.

1. Separate flows of goods (EMEBI and EU sales list) from flows of services (DES), transaction by transaction.
2. Check whether you are notified for the EMEBI and identify the direction of the flow: arrival (introduction) or dispatch (expedition).
3. Collect and validate the intra-EU VAT numbers of your EU customers and suppliers.
4. Enter nomenclature codes, values and weights for the EMEBI in notified months, nil return included.
5. File the EU sales list from the first euro, between the 1st and the 10th working day of the following month.
6. File the DES for services supplied to an EU taxable customer, no later than the 10th working day of the month following the month of chargeability.
7. Keep a monthly schedule and archive invoices, transport evidence and filing receipts.

The most costly confusion is not technical, it is conceptual: believing the DEB still exists as a one-stop form. In practice, the same EU partner can require an EU sales list (for goods sold) and a DES (for an associated service such as transport or installation). Separating flows at invoicing, not at filing, removes most errors.

The second point we stress: not owing the EMEBI never cancels the tax obligation. Many directors, relieved not to be notified for the EMEBI, wrongly conclude they have nothing to file. The EU sales list and the DES remain due from the first euro.

The discrepancy between VAT and the periodic declarations is the first signal scrutinised. If your exempt intra-EU supplies appear in your VAT returns but not in the EU sales list, or if a reverse-charged service is missing from the DES, the gap is immediately visible by cross-checking. A poorly justified exempt intra-EU supply may have its exemption challenged, which makes the VAT due.

Recently, a director of an industrial SME contacted us after receiving a reminder from customs. They sold parts to German and Italian customers, correctly declared their exempt supplies for VAT, but had never filed an EU sales list: they thought the absence of an EMEBI notification meant a full exemption. We reconstructed the missing statements by reference month and secured consistency with the VAT returns. The issue was not good faith, but confusion between the statistical part and the tax part, exactly the trap this article seeks to avoid.

The filing calendar works in working days, not calendar days: the window from the 1st to the 10th working day shifts each month with weekends and public holidays. The nil return for a notified EMEBI is a full obligation, not an option. Finally, the validity of your partners' intra-EU VAT numbers conditions the exemption of supplies and the reverse charge: an invalid number weakens the whole chain. A tool such as Pennylane or Qonto helps track flows but does not replace checking the invoice details.