Guide
Trading with Northern Ireland under the Windsor Framework
How UK businesses move goods between Great Britain and Northern Ireland under the Windsor Framework. Covers UKIMS authorisation, NIRMS for food products, EORI numbers, customs declarations, duty relief, and VAT requirements.
The Windsor Framework governs trade between Great Britain (England, Scotland, Wales) and Northern Ireland. It creates simplified arrangements for most goods while ensuring compliance with the UK's international commitments.
This guide explains what you need to do to move goods between GB and NI, whether you're a GB business selling to NI customers or an NI business receiving goods from GB suppliers.
Getting your EORI numbers
Before you can move goods between GB and NI, you need the right EORI (Economic Operators Registration and Identification) numbers. The requirements differ depending on where your business is based.
Which EORI number do you need?
- GB-based business moving goods to NI: You need a GB EORI. An XI EORI is only needed if you're also trading with the EU via NI
- NI-based business: You need both GB and XI EORI numbers to access both markets
- EU business selling to NI: You need an XI EORI to make customs declarations
Apply for your EORI numbers through HMRC's online service. GB EORI is usually issued immediately; XI EORI takes up to 5 working days.
UK Internal Market Scheme (UKIMS)
UKIMS is the authorisation that allows your goods to move through the simplified "green lane" without full customs declarations. If you regularly move goods from GB to NI, you should apply for UKIMS authorisation.
Should you apply for UKIMS?
Yes, apply if:
- You regularly move goods from GB to NI (more than occasional shipments)
- Your goods are for the NI market, not for onward movement to the EU
- You want to avoid full customs declarations and duty payments
You may not need UKIMS if:
- You're sending consumer parcels (the carrier handles this under the UK Carrier Scheme)
- Your goods are low value (under £135) and "not at risk" of entering the EU
- You're making one-off or very occasional shipments
What this means for online retailers
- Consumer deliveries: No customs declarations needed - your carrier shares standard commercial data with HMRC
- Business deliveries: Either you or the recipient needs UKIMS authorisation, or the carrier submits a CDS declaration
- UK Carrier Scheme: Major carriers like Royal Mail, Parcelforce, DPD handle compliance automatically for consumer parcels
In practice, most GB retailers can ship to NI consumers exactly as they ship to England or Wales.
Moving food and agrifood products (NIRMS)
The Northern Ireland Retail Movement Scheme (NIRMS) provides simplified arrangements for moving prepacked retail agrifood goods from GB to NI. This replaces the previous STAMNI scheme.
"Not for EU" labelling requirements
Goods moving under NIRMS must carry "Not for EU" labelling to show they're not intended for the EU market. These requirements are being phased in:
Labelling guidance
- Labels must be clearly visible and non-removable
- Can be on the product packaging or a separate label
- 30-day grace period after each phase for existing inventory
- Check APHA guidance for specific product requirements
Duty relief and reimbursement
Even if your goods are classified as "at risk" and you pay EU duty, you may be able to reclaim it or have it waived.
Customs Duty Waiver Scheme
Under de minimis aid rules, duty can be waived up to certain limits:
VAT for Northern Ireland trade
Northern Ireland has a unique VAT position - it follows UK VAT rules for goods but is treated as part of the EU for VAT purposes. This affects how you account for VAT on cross-border sales.
Step-by-step: Setting up for NI trade
- Get your GB EORI: Apply through HMRC if you don't have one
- Register for Trader Support Service: Free service that can handle declarations for you
- Apply for UKIMS: For simplified GB to NI movements of qualifying goods
- Set up Trader Goods Profile: Pre-declare your common goods and suppliers
- Register for NIRMS: If you're moving food or agrifood products
- Get XI EORI (if needed): Required for EU trade via NI