Your company has been incorporated in France, the goods have arrived at a French port or airport, and the carrier now says that the first shipment is “blocked at customs”. For a foreign founder, this message is rarely precise enough to tell you what to do. The obstacle may be a missing Economic Operators Registration and Identification number, a mismatch between the company’s legal identity and its French value-added tax number, an incomplete commercial invoice, an uncertain commodity code, a missing product certificate, or a customs control that cannot be solved by simply paying a carrier’s invoice. The first objective is therefore to identify the exact procedural status of the goods, the person who filed the customs declaration, and the document or data that is missing. This article explains the legal framework applicable on 28 August 2026 and gives a practical recovery plan for a French subsidiary, branch or company owned from abroad. It also separates customs duties, import VAT, contractual claims against a supplier or forwarder, and formal appeals. The recent EORI SIREN transition and the planned changes to the French tax-code provisions make a dated verification essential before the next shipment.

I. Why is a first French import shipment blocked at customs?

A. Who is the importer, the declarant and the customs representative?

A shipment arriving from outside the European Union does not become a French import merely because a French address appears on the delivery label. The legal analysis begins with the goods, the sales chain and the customs declaration. A purchase from a supplier established in another EU Member State is generally an intra-Union movement, not an import into France. A shipment from the United Kingdom, the United States, Switzerland, China or another non-EU country normally requires a customs procedure before the goods can be released for free circulation in France.

For value-added tax purposes, Article 291 of the French General Tax Code states: Les importations de biens sont soumises à la taxe sur la valeur ajoutée. The provision defines an import by reference to the entry into France of goods originating in or coming from a country or territory outside the European Union which have not already been released for free circulation. This is different from the commercial question of who owns the goods and from the Incoterm written in the supplier’s contract. An Incoterm allocates costs, transport risk and certain tasks between the contracting parties; it does not by itself determine whether the French company is correctly registered with customs or who may be liable for inaccurate information.

Four roles must be identified in writing:

• The importer or consignee. This is the company for which the goods enter the customs territory and which expects to use, resell or transform them. A French subsidiary may be the importer even though its foreign parent negotiated the purchase.
• The declarant. This is the person who lodges the customs declaration. The carrier, express operator, freight forwarder or customs broker may file it, but the company must obtain a copy and understand the capacity in which it was filed.
• The customs representative. Under Article 18 of Regulation (EU) No 952/2013 establishing the Union Customs Code, Toute personne peut désigner un représentant en douane. Representation may be direct, in the name and on behalf of the company, or indirect, in the representative’s own name but for the company’s account. The distinction affects the allocation of customs and tax exposure.
• The seller and the transport contractor. They may have contractual duties to provide accurate invoices, packing data, origin evidence or transport information, but their duties do not eliminate the need for the French company to control the declaration that is submitted in its name or for its account.

A foreign parent should not assume that its French company can use the parent’s customs identity without checking the legal structure. For a French establishment, an EORI number is connected to the operator’s registration data. EORI means Economic Operators Registration and Identification. SIREN means the nine-digit national identification number of a French legal entity; SIRET means the fourteen-digit identification number of a particular establishment. The French customs administration explains the EORI and SIREN transition in its official EORI guidance. Its current guidance states that the EORI SIREN is intended to be the unique identifier for French operators, while older EORI SIRET records are being phased out according to the administration’s timetable.

The tax identity must be checked separately. Article 286 ter of the French General Tax Code begins: Est identifié par un numéro individuel : It includes an assujetti, meaning a person carrying on an economic activity for VAT purposes, who is liable for VAT on imports. The company’s French VAT number must be valid, connected to the correct legal entity and communicated in the customs declaration when the import-VAT mechanism requires it. A French VAT number, an EORI number and a foreign parent’s VAT number are not interchangeable.

Nor should a company confuse EORI with a Kbis. A Kbis is the official extract showing the registration of a commercial company in the French commercial register. The greffe is the clerk’s office of the competent commercial court. Since the move to the Guichet unique, the single online business-formality portal operated through the Institut national de la propriété industrielle (INPI), many registrations are filed into the Registre national des entreprises (RNE), the National Business Register. A Kbis can help prove the company’s identity and powers, but it is not a substitute for the EORI or for an import-capable VAT registration.

The first practical request to the forwarder is therefore not “please release the goods”. Ask for the Movement Reference Number (MRN), the customs office handling the declaration, the declaration status, the exact error message, the EORI used, the VAT number used, the type of representation, and the name of the person who lodged the declaration. Ask whether the goods are merely awaiting information, selected for documentary control, selected for physical examination, subject to a product restriction, or already the subject of a formal decision. Those are different situations with different next steps.

A useful cross-check is the French customs administration’s EORI validity service. The administration warns that EORI registration is free and that websites offering a paid number may be fraudulent. Keep a screenshot or downloaded result in the shipment file. The French company should also link its customs profile, professional email address and authorised users to the correct legal entity rather than relying on an account controlled only by the foreign parent or by a logistics provider.

B. Which document, classification or tax data is actually missing?

“Blocked” is not a legal diagnosis. The second stage is a document-by-document reconciliation of what the customs declaration says with what the goods, contract and company records actually show. The declarant’s responsibility is serious because Article 15 of the Union Customs Code makes the person lodging a declaration responsible for the accuracy and completeness of the information and for the authenticity, accuracy and validity of supporting documents. The company should not solve a delay by asking a broker to guess a lower value, a more convenient origin or a generic product description.

For a first commercial shipment, assemble a single indexed file containing at least:

• the purchase order, signed contract and commercial invoice, including currency, payment terms, seller and buyer identities;
• the packing list, transport document, package count, weights, dimensions and precise description of every product;
• the company’s EORI confirmation, SIREN or SIRET details, French VAT number and the identity of the legal representative;
• the customs mandate or power of attorney proving whether the broker acts directly or indirectly;
• the proposed Harmonised System or Combined Nomenclature commodity code, with the technical description used to justify it;
• the country of origin evidence, any preferential-origin statement and any proof needed to claim a tariff preference;
• the transport cost, insurance cost, assists, royalties, commissions and other elements that may affect customs value;
• product certificates, conformity documents, licences, sanitary or phytosanitary documents and labelling evidence where the product category requires them;
• the carrier’s arrival notice, MRN, customs correspondence, requests for information and any storage or demurrage notice; and
• the accounting and tax plan for customs duty, import VAT and the French VAT return.

Classification is often the hidden issue. “Machine”, “sample”, “component”, “cosmetic”, “food supplement” or “electronic device” is not usually precise enough. The customs code can change the duty rate, licensing requirements, trade-defence measures and product controls. The commercial invoice must describe what the goods are, what they are made of, what they do and how they are packaged. If the product has several possible uses, document the principal function and obtain technical sheets from the supplier. If the tariff classification is genuinely uncertain, consider a binding tariff-information application before future shipments rather than repeating the dispute at the border.

Origin is not the same as the country from which the parcel was shipped. A product manufactured in one country, sold by a company in a second country and shipped through a third country may require a separate origin analysis. A preferential rate can depend on a specific proof and on the relevant trade agreement. Do not copy a “made in” label into the customs declaration without checking the origin rules for the product.

Customs value also requires discipline. Article 292 of the French General Tax Code states: La base d’imposition est constituée par la valeur définie par la législation douanière conformément aux règlements communautaires en vigueur. It then includes, among other items, import duties and taxes other than VAT and accessory costs such as commission, packaging, transport and insurance up to the first destination in France. The invoice price is not automatically the full taxable base, and a related-party transaction may require additional supporting information. Keep the freight and insurance figures consistent across the invoice, transport file and declaration.

Import VAT follows its own legal logic. Article 293 A of the French General Tax Code provides: A l’importation, le fait générateur se produit et la taxe devient exigible au moment où le bien est considéré comme importé. The same article requires the liable taxable person to communicate a valid identifier to the administration handling the customs declaration. A foreign-owned French company must therefore make sure that the EORI, French VAT number, customs declaration and import accounting all point to the same transaction.

For a company identified for VAT in France, import VAT is generally reported through the French VAT return rather than treated as a simple carrier cash collection. The French customs administration describes automatic import-VAT self-accounting in its official procedure. Self-accounting means that the company reports output and deductible import VAT on its periodic return; it does not mean that customs duties disappear, that an invalid VAT number is acceptable, or that the company can omit the transaction from its records.

Article 271 of the French General Tax Code says that deductible VAT includes, for imports, the tax paid by the taxable person itself, subject to the statutory conditions. Its wording includes: La taxe sur la valeur ajoutée qui a grevé les éléments du prix d’une opération imposable est déductible de la taxe sur la valeur ajoutée applicable à cette opération. The company must preserve the import declaration or the documents transmitted by the customs representative, the taxable base and the declaration reference. A broker’s informal email saying “VAT cleared” is not enough evidence for the accounts.

The reporting obligation is not optional merely because the company has made only one import. Article 287 of the French General Tax Code states: Tout redevable de la taxe sur la valeur ajoutée identifié conformément aux dispositions combinées des articles 286 ter et 286 ter A est tenu de remettre au service des impôts dont il dépend … une déclaration conforme au modèle prescrit par l’administration. In practical terms, the French company should coordinate the customs broker, its accountant and its Service des impôts des entreprises (SIE), meaning the business tax office, before submitting the first return affected by the import.

There are exceptions and transitional rules. Article 286 ter A provides, in specific situations, that taxable persons are not required to identify themselves by an individual number, including certain occasional or exempt operations. Article 1695 still contains a separate rule for imports where the liable person is not subject to VAT or is not identified, stating: La taxe sur la valeur ajoutée est déclarée et perçue lorsqu’elle devient exigible for the listed situations. These provisions have future abrogation and replacement dates in the version currently shown by Légifrance. The correct treatment must be checked against the date of the import and the company’s actual status, especially around the 2026 transition.

A company should also distinguish a customs hold from a product-safety refusal. Customs may request evidence of conformity, an import licence, a sanitary document, a strategic-goods authorisation, a protected-species document or another regulatory clearance. If the goods are counterfeit, prohibited, unsafe or misdeclared, the matter can escalate beyond a routine missing-document request. Preserve the original packaging and do not destroy, relabel or return the goods before the customs position is understood.

II. What should a foreign-owned French company do to release the shipment?

A. Follow a controlled 24-hour recovery workflow

The company’s first response should be coordinated, written and time-stamped. Create one internal incident record and nominate one person in France to communicate with the declarant, carrier, accountant and foreign management. Multiple employees sending inconsistent invoices or authorisations creates a second problem and can make it difficult to prove which information was approved.

1. Freeze the facts. Save the carrier message, the tracking history, the arrival notice, the invoice, packing list, purchase order, transport document and every customs request. Record the time at which storage charges began and the contractual delivery date. Do not accept an unexplained change in the description, value or origin.
2. Obtain the customs reference. Ask the declarant for the MRN, customs office, declaration type, status, EORI, French VAT number, representation type and the precise reason for the hold. Ask directly whether the goods have been selected for documentary or physical control and whether a formal written decision has been issued.
3. Check the legal entity. Compare the company name, registered office, Kbis or RNE record, SIREN, bank details, EORI and French VAT number. If the foreign parent’s name appears as importer while the French subsidiary is the actual buyer, stop and obtain legal and customs advice before correcting the declaration.
4. Check the mandate. Require the broker to identify whether the declaration was lodged in direct or indirect representation. Ask for the signed mandate, the broker’s terms, the declaration copy and the data transmitted to customs. The company should know who can submit a correction and who is exposed if information was false or incomplete.
5. Build the evidence pack. Put the invoice, technical sheet, commodity-code explanation, origin proof, freight calculation, certificates and company identifiers in a numbered PDF or data package. Each response should answer the customs question and refer to the supporting document.
6. Correct before release where possible. If the issue is an error in the declaration, ask the declarant to submit the appropriate amendment or to explain why an amendment is legally unavailable. Do not assume the broker can rewrite the declaration after customs has notified an examination or identified an inaccuracy.
7. Separate duty from import VAT. Calculate customs duty, import VAT, storage, brokerage and transport charges separately. If the company qualifies for French import-VAT self-accounting, confirm that the French VAT number and required declaration data were included. Do not pay a carrier’s “VAT” invoice twice without reconciling the customs record.
8. Escalate a formal decision. If customs refuses release, imposes a reassessment, seizes the goods or gives a decision affecting the company directly, obtain the written legal basis and the appeal instructions. A phone call may unblock a missing document; it does not replace a formal challenge where rights and deadlines are at stake.

Correction has limits. Article 173 of the Union Customs Code allows the declarant, on request, to rectify one or more particulars after acceptance, but the rectification cannot turn the declaration into one covering different goods. The regulation also limits amendment after customs has informed the declarant that it intends to examine the goods, established that the particulars are incorrect, or released the goods. After release, an amendment may still be possible in defined circumstances and within the applicable period. The broker should provide the legal basis for the route proposed, not only a software explanation.

The following decision table helps a management team choose the first escalation:

Observed message	First question	Immediate action
“EORI missing or invalid”	Which legal entity and identifier were used?	Validate the EORI, compare it with the SIREN or foreign-operator record, then ask the declarant whether a new declaration or amendment is required.
“VAT number missing or rejected”	Was a valid French VAT number required for this import?	Contact the SIE or Direction des grandes entreprises (DGE), the Large Business Tax Directorate, and reconcile the customs data with the VAT return.
“Invoice, value or origin required”	Can the figure or origin be proved from contemporaneous records?	Send the contract, invoice, freight calculation, payment evidence and origin documents; never invent a retroactive explanation.
“Classification or licence problem”	Does the product require a permit or technical conformity document?	Obtain the technical file and regulatory advice; a customs broker alone may not be qualified to resolve a product-law issue.
“Control, seizure or formal refusal”	Has a written decision been issued, and what deadline applies?	Secure the goods and evidence, preserve appeal rights and obtain counsel quickly, especially if destruction, re-export or penalties are mentioned.

The French customs administration’s import-VAT procedure states that a company without a valid French intra-Community VAT number that wishes to import in France must contact the tax authorities to obtain one and must report it on its customs declarations. The same source explains that the online VAT return, commonly called the CA3, can be pre-completed from customs data. CA3 is the French form used for the periodic VAT return. This administrative connection is valuable, but it does not cure a wrong importer name, an incorrect classification or missing product authorisation.

Keep a separate cash-flow calculation. Customs duty is a customs liability calculated by reference to the tariff classification, origin and customs value. Import VAT is a VAT liability calculated on the legally defined base. The broker’s clearance fee, port storage, terminal handling, demurrage and insurance are contractual or logistical costs. A foreign founder should ask the accountant to map each amount to the proper invoice, tax account and supporting document. The company should also check whether the supplier charged foreign VAT incorrectly; that issue may require a credit note and is not the same as French import VAT.

B. Protect the company’s rights and allocate responsibility after the hold

A first shipment may be delayed because the supplier sent incomplete information, the carrier filed a declaration without confirming the mandate, the broker selected the wrong commodity code, or the French company gave an inaccurate description. Responsibility cannot be allocated by looking only at the party that sent the last email. Review the contract, purchase order, freight terms, customs mandate, broker’s general conditions and the actual declaration.

Under Article 1103 of the French Civil Code, Les contrats légalement formés tiennent lieu de loi à ceux qui les ont faits. Under Article 1104, contracts must be negotiated, formed and performed in good faith. These rules do not transfer a public customs obligation to a supplier automatically, but they help assess whether a contractual party failed to provide documents, used a carrier without authority or withheld information needed for clearance.

If the hold has caused a material delay, the company should quantify the loss rather than merely complain. Record storage, demurrage, missed customer deliveries, replacement transport, lost production time, financing cost and any product deterioration. Check the liability caps, notice periods and exclusions in the carrier and broker terms. If the supplier failed to deliver an agreed document or provided a materially inaccurate invoice, send a focused formal notice identifying the breach, the corrective action requested and the evidence.

Article 1217 of the French Civil Code lists the remedies available to the party facing non-performance, including suspension, forced performance, price reduction, termination and compensation. Its text states: La partie envers laquelle l’engagement n’a pas été exécuté, ou l’a été imparfaitement, peut : The remedy must match the contract and the facts. A company should not suspend a supplier payment or terminate a strategic supply agreement without considering the consequences and the contractual procedure.

For damages, Article 1231-1 of the French Civil Code provides: Le débiteur est condamné, s’il y a lieu, au paiement de dommages et intérêts soit à raison de l’inexécution de l’obligation, soit à raison du retard dans l’exécution, s’il ne justifie pas que l’exécution a été empêchée par la force majeure. The company must still prove the obligation, breach, causal link and recoverable loss. Customs delay caused by a lawful control or by the importer’s own missing documents will not automatically produce a claim against the forwarder.

When a money obligation is due, Article 1344 of the French Civil Code defines formal notice as a demand or act containing a sufficient formal reminder, or, where the contract provides, the mere due date. A properly documented notice is more useful than a chain of angry messages. It should identify the consignment, the contractual obligation, the missing document, the cost incurred and the deadline for the proposed correction.

The company must also protect itself against an incorrect customs narrative. If the broker says that a declaration was filed in the company’s name, obtain the data submitted and compare it with the source documents. If an employee or foreign parent approved an inaccurate value or origin, preserve the internal approval trail and seek advice before making a second statement. If the goods are controlled or seized, never ask a carrier to conceal, relabel, abandon or destroy them to avoid a formal record.

There is a right of appeal against an individual customs decision. Article 44 of the Union Customs Code provides in French: Toute personne a le droit d’exercer un recours contre les décisions relatives à l’application de la législation douanière prises par les autorités douanières et qui la concernent directement et individuellement. The right is exercised in at least two stages under the regulation. However, an appeal does not automatically suspend implementation. The company must therefore read the decision, check the appeal body and deadline, and ask whether a suspension or guarantee is available. A carrier tracking note is not always a decision within the meaning of the appeal rules; obtain the official document.

The tax consequences also need a separate check. Article 1788 A of the French General Tax Code provides fines for certain VAT reporting and record-keeping failures, including omissions or inaccuracies in specified statements and documents. The precise paragraph and date must be checked before drawing a penalty conclusion. A company that discovers an error should document the correction, tell its accountant, and avoid silently carrying an incorrect customs base into a later VAT return.

The best prevention is a written import protocol before the second shipment. It should state who is importer of record, who signs the customs mandate, which EORI and French VAT number are authorised, who approves the commodity code and origin, what documents suppliers must deliver, who checks licences and product conformity, how corrections are approved, and where the final customs declaration is archived. The foreign parent should receive reports, but the French company should retain operational control of its own identifiers and evidence.

For a company that is still completing its French structure, the import protocol should be coordinated with the wider French company formation and international business framework. That pillar page is the appropriate internal hub for questions about the subsidiary, branch, registered office and first compliance steps. The existing EORI registration article can then be used for the identifier-specific procedure; this article addresses the distinct crisis that arises when the first shipment is already waiting at customs.

Do not treat the following dates as permanent advice. Légifrance currently displays changes to several French General Tax Code provisions governing import VAT and their replacement by the Code of Impositions sur les Biens et Services. The import date, the date of acceptance of the declaration and the company’s VAT status may determine which text applies. A foreign-owned business should preserve the version of the official text consulted and obtain a fresh confirmation when a shipment falls around a legislative transition.

Conclusion

A first French import shipment is usually released faster when the company replaces the vague word “blocked” with a written diagnosis: which goods, which declaration, which legal entity, which EORI, which French VAT number, which representative, which missing document and which deadline. The recovery sequence is to secure the MRN and status, reconcile the declaration with the commercial and technical file, correct only through the lawful customs route, separate duty from import VAT, and preserve evidence of every instruction. If a supplier, carrier or broker caused the delay, contractual remedies and quantified losses should be assessed independently of the public customs process. If customs issued a refusal, reassessment or seizure decision, obtain the decision and protect the appeal deadline. That disciplined approach gives a foreign founder a realistic path to release the goods and a stronger control system for future French operations.

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