Non-EU imports 2026: customs duties, VAT and EORI for French SMEs

Updated 24 May 2026 — written by Hayot Expertise, chartered accountant (expert-comptable) in Paris 8.

Since Brexit, the widening of European customs borders and the surge in cross-border trade from Asia and North America, customs has become a central item on the fiscal and logistics agenda of SMEs. In 2026, a new player joins the picture: the Carbon Border Adjustment Mechanism (CBAM), whose definitive phase started on 1 January 2026.

This guide draws on official sources — douane.gouv.fr, impots.gouv.fr and the European Commission — to map every obligation facing a French SME or e-commerce operator importing from outside the EU in 2026: EORI, tariff classification, customs valuation, reverse-charge VAT, incoterms and CBAM.

Three trends explain why customs has returned to directors' to-do lists:

1. Brexit turned historically intra-EU flows into full customs flows. Anything coming from Great Britain (excluding Northern Ireland) now triggers a formal customs declaration, tariff classification and potential duties.
2. The explosion of extra-EU e-commerce — marketplaces hosting Chinese or Turkish vendors — pushed the EU to tighten controls: abolition of the €22 VAT exemption on low-value shipments (from 1 July 2021), the IOSS (Import One Stop Shop) scheme, and the announced abolition of the €150 customs de minimis.
3. CBAM, now in its definitive phase since 1 January 2026, prices imported carbon across six sensitive sectors. Importers must purchase CBAM certificates corresponding to the carbon footprint of the product.

The EORI (Economic Operators Registration and Identification) number is the unique identifier for economic operators in the EU. No extra-EU import is possible without an EORI number.

How to obtain it#

• Online application via the SOPRANO online service on douane.gouv.fr (section "Professionnels").
• Documents: Kbis extract less than 3 months old, INSEE certificate, completed EORI form.
• Processing time: a few business days.
• Cost: free.
• French format: FR + SIREN + 00000 (by default).

Customs representation#

The importer may handle its own operations or appoint a registered customs representative (RDE — représentant en douane enregistré), under two modes:

• Direct representation: the RDE acts in the importer's name; sole fiscal liability remains with the importer.
• Indirect representation: the RDE acts in its own name, with joint and several liability towards customs.

For an e-commerce SME, direct representation by a customs broker remains the standard solution.

Reading TARIC via RITA#

TARIC is the EU's integrated tariff database, accessible to all via the EU portal or through RITA (France's tariff encyclopaedia) on douane.gouv.fr. Each product is classified under a 10-digit HS code (Harmonised System):

• First 6 digits: worldwide nomenclature (World Customs Organization).
• 8 digits: EU Combined Nomenclature.
• 10 digits: TARIC code (additional EU measures: quotas, anti-dumping, suspensions).

The classification drives the duty rate (from 0% to over 30% depending on the product), trade-policy measures (quotas, embargoes, tariff-rate quotas) and preferential regimes under EU free-trade agreements.

Binding Tariff Information (BTI)#

Where the classification is uncertain, it is possible to request a Binding Tariff Information (BTI — Renseignement Tarifaire Contraignant) from the French Customs directorate (handled by the Lille office for France). The BTI:

• is issued free of charge;
• binds the administration for 3 years;
• secures the classification against any future reassessment.

In practice. For a complex product — technical textiles, combined electronics, composite food ingredients — requesting a BTI ahead of a first large import is a time investment that pays off against the risk of reclassification and a customs reassessment.

Customs valuation#

Article 70 of the Union Customs Code (EU Regulation 952/2013) sets the primary method: transaction value, increased by transport and insurance costs up to the EU point of entry. The following are added to the transaction price:

• commissions borne by the buyer (excluding purchasing commissions);
• royalties and licence fees relating to the goods;
• the cost of materials supplied by the buyer;
• packaging costs;
• transport and insurance up to the EU point of entry.

The following are excluded: post-clearance costs, any VAT service fee, discounts unrelated to the intrinsic value of the goods.

Incoterms 2020#

Incoterms define who pays what and who bears the risk. The most common in extra-EU e-commerce:

Important: under DDP, the foreign seller becomes the legal importer in France and must register for EORI and French VAT. This is often impractical, and the DGFiP regularly re-characterises these transactions.

Since 1 January 2022 (article 1695 of the French Tax Code — CGI), import VAT is automatically reverse-charged by every French VAT-registered entity holding an EORI number.

How it works in practice#

• VAT is no longer paid at the point of clearance.
• The relevant line on the CA3 return (monthly or quarterly VAT return) is pre-filled by the DGFiP using customs data transmitted by the DGDDI.
• The amount is both collected and deducted on the same return → cash-flow neutrality, except for operators with a restricted deduction ratio (partly exempt activities).

For operators not registered in France#

A foreign operator importing under DDP without a French establishment must register for French VAT before the first import. Fiscal representation is no longer required for EU operators (since 2021) but remains mandatory for most non-EU operators.

Cross-border B2C extra-EU sales of low value (≤ €150 excluding tax) benefit from the IOSS scheme:

• the seller (or the marketplace) charges French VAT at the time of sale;
• declares and remits it through a single IOSS return in its EU country of identification;
• the shipment is exempt from import VAT but remains subject to customs duties where applicable above €0 (the €150 exemption applies to duties, not to VAT).

For marketplaces (Amazon, eBay, AliExpress, Shein, Temu, etc.), Directive (EU) 2017/2455 places VAT collection obligations on the platform in several scenarios. See our DAC 7 platforms guide 2026 for the reporting dimension.

Abolition of the €150 de minimis announced. The European Commission proposed in 2023 to scrap the €150 customs duty exemption in parallel with a broader recast of the EU Customs Code. The adoption timetable is not final at the date of publication, but extra-EU e-commerce operators should build this scenario into their financial modelling.

The Carbon Border Adjustment Mechanism (EU Regulation 2023/956) aims to price imported carbon at the EU rate. Six sectors are in scope: cement, iron and steel, aluminium, fertilisers, electricity, hydrogen.

Transitional phase (completed end of 2025)#

• Quarterly emissions declarations, without purchasing certificates.
• Operator familiarisation and data collection.

Definitive phase (from 1 January 2026)#

• The importer declares the intrinsic emissions of the CBAM products imported.
• It purchases CBAM certificates corresponding to the carbon footprint, at the EU ETS price.
• Certificates are sold by national authorities (in France, the DGEC).

De minimis threshold#

Shipments with a value below €50 are exempt. The threshold is assessed consignment by consignment, which creates practical complexity for e-commerce flows of luxury goods and raises questions about aggregated bulk industrial shipments.

Our expert view, based on client files accompanied in 2024–2026.

1. Incoterm/VAT-registration mismatch. A DDP seller with no French VAT registration is exposed to a reassessment. The legal importer must always be clearly defined in the contract.
2. Approximate HS classification on product catalogues. Customs routinely reassesses when a textile product is classified under HS 6204 when it falls under HS 6104 (jersey knit vs woven). A BTI eliminates this risk.
3. Understated customs value by excluding licence royalties. A brand carried under licence on an imported product requires the royalty to be added to the customs value.
4. CBAM blind spots on apparently innocuous products (steel bolts, aluminium profiles, composite fertilisers). The scope of CBAM HS codes is broad and will expand in stages.

How do I obtain an EORI number in France?#

Via the SOPRANO online service on douane.gouv.fr: Kbis less than 3 months old, INSEE certificate, completed EORI form. Issued free of charge within a few business days.

What is the difference between customs duties and import VAT?#

Customs duties are an EU resource assessed on the customs value of the goods at the TARIC rate for the HS code. Import VAT is a French resource assessed on the customs value plus duties, at the applicable product rate. Since 2022, import VAT is reverse-charged on the CA3 return (article 1695 CGI).

How does reverse-charge import VAT work in 2026?#

Every French VAT-registered company holding an EORI number automatically reverse-charges import VAT on its CA3 return. No cash outlay is required at the point of clearance. The relevant line is pre-filled by the DGFiP.

Does an SME need a customs representative?#

Not legally, but it is almost always the practical norm. A customs broker secures HS classification, customs valuation and access to special procedures. Direct representation keeps fiscal liability with the importer; indirect representation makes the broker jointly and severally liable.

Does CBAM apply to my business?#

If you import cement, iron and steel, aluminium, fertilisers, electricity or hydrogen from outside the EU, yes. The definitive phase began on 1 January 2026 (certificate purchase required). De minimis threshold: €50 per consignment.