How the mechanism works
Before 2022, when goods entered France from outside the EU, the importer paid the French import VAT in cash to customs at the time of clearance and then recovered it, weeks later, on a VAT return. The reform removed the cash step. Today, the moment your customs declaration clears, the import VAT is self-assessed: it is simultaneously declared as output tax and deducted as input tax on the same CA3 return. For a fully taxable operator with full deduction rights, the net cash impact is zero. For a partly exempt operator, the net is the non-deductible fraction, and it appears in a single place instead of being split between a customs payment and a later return adjustment.
Who qualifies and who does not
The reverse charge is compulsory for every importer of record holding a French VAT number at the moment of clearance. That includes non-EU companies acting through a fiscal representative; the representative holds the French VAT number on the company's behalf, and the mechanism applies as if the non-EU company were a local taxpayer. What it does not cover is a private individual importing goods on their own name, a foreign company without a French VAT number that tries to clear goods through a third-party consignee, or a supplier selling under Incoterms DDP where the buyer's VAT number is used but the contractual responsibilities sit elsewhere. In every one of those edge cases, French customs will refuse the reverse-charge routing and fall back to the pre-2022 cash model.
The CA3 flow, box by box
On the French monthly VAT return, form CA3, four lines matter. Line A4 receives the taxable base of imports at the applicable rate. Lines 08, 09, 09B receive the output VAT at 20, 10 or 5.5 per cent. Line 20 reclaims the same amount as deductible input VAT, provided the operator has full recovery rights. Line 24 captures any adjustment arising from a customs-value correction within the filing period. The DGFiP pre-fills A4 from the customs database, and the pre-fill is correct roughly 95 per cent of the time. Your fiscal representative verifies the pre-fill against the DAU customs declarations, corrects it where necessary, and documents the correction. This reconciliation is the single most time-consuming part of the representative's monthly workload since the 2022 reform.
Rates at a glance
View data as table
| Category | Rate |
|---|---|
| Standard (most goods and services) | 20% |
| Reduced (restaurant, transport, some works) | 10% |
| Reduced (food, books, gas and electricity) | 5.5% |
| Super reduced (press, reimbursable medicines) | 2.1% |
Worked example
A Canadian electronics brand, represented in France by an accredited firm, imports a shipment worth €600,000 through the port of Le Havre in March 2026. Customs value after adjustments: €612,000. At the 20 per cent standard rate, the import VAT is €122,400. Under the pre-2022 model, Canadian treasury would have wired €122,400 to French customs on clearance, waited six to eight weeks for the CA3 refund, and carried the cost of that delay. Under the current regime, the March CA3 shows €612,000 on line A4, €122,400 on line 08 as output VAT, and €122,400 on line 20 as deductible input VAT, net effect zero. The fiscal representative keeps copies of the DAU, the carrier's invoice, and the supplier's commercial invoice, and signs the return. Cash saved, risk shifted onto documentation quality.
Pitfall to avoid
The pitfall is treating the pre-filled A4 line as authoritative. The DGFiP imports customs data in near real time, but freight arriving late in the month, amendments to the DAU after clearance, and splits between two VAT numbers regularly produce a pre-fill that is out by a few thousand euros. If the representative files as-is, the error propagates into the input-VAT deduction, and the discrepancy surfaces at the next tax audit as either an over-deduction, interest and penalties, or an under-declaration, also interest and penalties. The administration knows this is a frequent mistake and the inspectors look for it first.
Pro tip
Reconcile the representative's CA3 A4 line to your own customs software before the 19th of each month, which is when most CA3 returns lock for filing. Ask your representative for a monthly reconciliation file showing the DAU numbers, declared value, VAT amount, and filing period. Any DAU that appears in your freight list but not in the representative's file is a missed import; any that appears in theirs but not yours is a stray clearance against your EORI, sometimes the start of an identity-theft issue. Catching both types of discrepancy inside the same month keeps everything within the correction window, outside, corrections become a separate penalty exercise.
Key takeaways
- Since January 2022, French import VAT is self-assessed on the CA3 return, not paid at customs.
- The mechanism is compulsory for every holder of a French VAT number; it applies through your fiscal representative.
- Check the pre-filled A4 line every month; the 5 per cent error rate is systemic, not exceptional.
- Keep DAU, carrier, and supplier documents for every import; the representative is audited on them.
- The reform saves cash but transfers the compliance burden from customs clearance to the CA3 filing workflow.
Frequently asked questions
Is the reverse charge optional?
No. Since 1 January 2022, the reverse-charge mechanism applies automatically to every importer holding a French VAT number. There is no opt-in form and no way to revert to cash payment at customs.
Do I still need a customs representative?
Yes, if you do not hold an EORI number or a French establishment. The customs representative handles the DAU clearance; the fiscal representative handles the VAT treatment downstream. They are two jobs, often done by the same group but by different teams.
What happens if the pre-filled line is wrong?
You correct it manually on the return and keep the supporting customs documentation. The French tax administration accepts the correction if the underlying DAU proves the figure. Do not leave the pre-fill uncorrected thinking the administration will reconcile later; it will not.
Does the reverse charge apply to services?
The reverse-charge label is also used for intra-Community services under Article 44 of the VAT Directive, but that is a different mechanism with a different legal base. This page covers only import VAT on goods crossing the French border.