Selling products in Northern Ireland

If you are a GB-based business that manufactures or sells products and want to supply the Northern Ireland market, you need to understand NI's unique regulatory position. Under the Windsor Framework, Northern Ireland follows EU single market rules for goods while remaining part of the UK customs territory.

This means the product marking, conformity assessment, and labelling requirements in NI differ from those in England, Scotland, and Wales. Getting it wrong can mean your products are non-compliant and cannot legally be sold in NI.

The dual regulatory regime

Northern Ireland operates a dual regulatory regime for manufactured goods. This is the most important concept to understand before you sell into NI.

What the dual regime means for your business

For most product categories covered by EU product safety rules, you have a choice when placing goods on the NI market:

• Follow EU rules: Use CE marking based on conformity assessment by an EU Notified Body. Your products can then be sold in both NI and the EU single market.
• Follow UK rules with UKNI marking: If you use a UK-based Approved Body for conformity assessment instead of an EU Notified Body, your products must carry both CE and UKNI marking. These products can be sold in NI and GB, but not in the EU/EEA market.

You cannot use UKCA marking alone for products sold in Northern Ireland. UKCA marking is not recognised on the NI market.

UKNI marking: when and how to use it

The UKNI marking is specific to the Northern Ireland market. It indicates that a UK-based conformity assessment body (rather than an EU Notified Body) assessed the product.

When you do NOT need UKNI marking

Many products do not require UKNI marking at all:

• Self-declared products: If the relevant regulations allow the manufacturer to self-declare conformity (no third-party assessment needed), UKNI marking does not apply. Most lower-risk consumer products fall into this category.
• EU Notified Body assessment: If you chose to have your product assessed by an EU Notified Body, CE marking alone is sufficient for the NI market.

UKNI marking is only required when your product needs mandatory third-party conformity assessment and that assessment was carried out by a UK-based Approved Body.

'Not for EU' labelling

Certain goods moving from GB to NI under simplified arrangements must carry 'Not for EU' labelling. This requirement is being phased in and primarily affects food and agrifood products moving under the Northern Ireland Retail Movement Scheme (NIRMS).

The phased implementation:

• Phase 1 (from 1 October 2023): Individual labelling required for all meat products and some dairy products
• Phase 2 (from 1 October 2024): Extended to all remaining dairy products, composite products containing dairy, and mandatory across GB for meat, milk, and dairy
• Phase 3 (from 1 July 2025): Extended to composite products, unprocessed fruit and vegetables, fish, eggs, honey, and pet food

The labelling must be clearly visible, non-removable, and applied to the product packaging. For products without individual packaging, shelf-level labelling is required at retail premises in NI.

UKIMS membership

To move goods from GB to NI through the simplified green lane (UK Internal Market lane), you typically need authorisation under the UK Internal Market Scheme (UKIMS). This allows your goods to move with minimal checks and no customs declarations.

Apply for UKIMS through HMRC's online service. You will need:

• An EORI number (GB prefix for GB-based businesses)
• Details of the goods you typically move
• Evidence that your goods are destined for the Northern Ireland or wider UK market, not for onward sale to the EU

Without UKIMS authorisation, your goods may be routed through the red lane, which requires full customs declarations and may incur EU duties.

How to determine which rules to follow

Use this decision process to work out your compliance route:

1. Identify your product category: Determine which EU product safety directive or regulation applies to your product (for example, the Low Voltage Directive, Machinery Regulation, or Toy Safety Directive)
2. Check the assessment route: Does the relevant legislation require mandatory third-party conformity assessment, or can you self-declare?
3. Choose your conformity assessment body: If third-party assessment is needed, decide between an EU Notified Body (CE marking, access to NI and EU markets) or a UK Approved Body (CE + UKNI marking, access to NI and GB markets only)
4. Apply the correct marking: CE marking for EU-assessed products, CE + UKNI for UK-assessed products. Never UKCA alone for NI.
5. Register for UKIMS: If you regularly move goods from GB to NI, apply for UKIMS authorisation to use the green lane

Product categories affected

The dual regulatory regime applies to all manufactured goods covered by EU single market product safety rules that apply in NI. Key categories include:

• Electrical and electronic equipment (including low voltage and electromagnetic compatibility)
• Machinery and equipment
• Personal protective equipment (PPE)
• Toys
• Construction products
• Pressure equipment
• Medical devices
• Radio equipment
• Gas appliances
• Recreational craft

If your product does not fall under any EU product safety directive or regulation, the dual regime does not apply and standard UK-wide rules govern your product.