Windsor Framework: what businesses need to know

The Windsor Framework is the agreement that governs how goods move between Great Britain (England, Scotland, and Wales) and Northern Ireland. If your business trades across this border, you need to understand how it affects you.

This guide explains the key concepts in plain terms: what the Framework is, how the lane system works, whether you need UKIMS authorisation, and what product marking rules apply in Northern Ireland.

What is the Windsor Framework?

The Windsor Framework came into effect in October 2023, replacing the earlier Northern Ireland Protocol. It creates a system where most goods moving from GB to NI face minimal checks, while ensuring that the open border between Northern Ireland and the Republic of Ireland is maintained.

The key change from the Protocol is the introduction of a "green lane" for goods staying within the UK. This dramatically reduces paperwork for the majority of GB-NI trade.

Who does this affect?

The Windsor Framework affects you if:

• You sell goods from GB to customers or businesses in Northern Ireland
• You are based in NI and receive goods from GB suppliers
• You manufacture products that may be sold in both NI and the EU
• You send parcels from GB to NI addresses

If you only trade within GB, or only within NI, the Framework does not directly affect your business operations.

Green lane vs red lane: how goods are routed

The Framework uses a lane system to route goods based on where they will end up. Understanding which lane your goods use determines what paperwork and checks apply.

The green lane (UK Internal Market lane)

Goods that will stay in the UK qualify for the green lane. This means:

• No customs declarations required
• No duty to pay
• Simplified data submission through Internal Market Movement Information (IMMI)
• Minimal checks (only around 5% of consignments from July 2025)

To use the green lane, you typically need UKIMS authorisation (explained below), though there are exceptions for low-value goods and consumer parcels.

The red lane

Goods that are "at risk" of entering the EU single market go through the red lane. This applies if:

• The goods are intended for the EU (via the NI-Republic of Ireland border)
• You cannot demonstrate the goods will stay in the UK
• You do not have UKIMS authorisation

Red lane goods face full customs declarations and may be subject to EU duties. However, if goods ultimately stay in the UK, you can reclaim any EU duty paid through the Duty Reimbursement Scheme.

How to determine your lane

Ask yourself: will these goods stay in Northern Ireland or move on to the rest of the UK, or might they enter the EU?

If you are selling to a NI retailer who sells only to local consumers, your goods are almost certainly "not at risk" and qualify for the green lane. If you are supplying a distribution centre that serves both NI and the Republic of Ireland, some goods may need to go through the red lane.

UK Internal Market Scheme (UKIMS)

UKIMS is the authorisation scheme that allows your goods to move through the green lane. It replaced the earlier UK Trader Scheme in September 2023.

Do you need UKIMS?

You should apply for UKIMS if:

• You regularly move goods from GB to NI (not just occasional shipments)
• Your goods are for the Northern Ireland market, not for onward sale to the EU
• You want to avoid full customs declarations and potential duty payments

You may not need UKIMS if:

• You only send consumer parcels (your carrier handles this under the UK Carrier Scheme)
• Your goods are low value (under 135 pounds) and clearly "not at risk"
• You make very occasional, one-off shipments

How to apply

Apply for UKIMS through HMRC's online service. The application is free, but you will need:

• An EORI number (GB prefix for GB businesses, XI prefix for NI businesses)
• Details of the goods you typically move
• Evidence that your goods are for the UK market

Processing typically takes a few weeks. Once authorised, set up your Trader Goods Profile to pre-declare your common product types and suppliers, which simplifies ongoing movements.

Product marking in Northern Ireland

Northern Ireland occupies a unique position: it is part of the UK but follows EU single market rules for goods. This has important implications for product marking.

CE vs UKCA marking

This is one of the most important practical differences between GB and NI markets:

In Northern Ireland: CE marking is required for products covered by EU product safety rules. UKCA marking alone is not accepted.

In Great Britain: UKCA marking is required (CE marking is being phased out for most products).

If you manufacture products that you sell in both GB and NI, you may need both CE and UKCA marks, or use CE marking throughout (which is accepted in GB until further notice for most products).

"Not for EU" labelling

Certain goods moving from GB to NI under simplified arrangements must carry "Not for EU" labelling. This applies particularly to food and agrifood products moving under the Northern Ireland Retail Movement Scheme (NIRMS).

The labelling must be:

• Clearly visible
• Non-removable
• Applied to the product packaging or a separate label

These requirements are being phased in by product type, with full requirements in place from July 2025.

Key dates and deadlines

The Windsor Framework is being implemented in phases. These are the dates you need to know:

What the dates mean for your business

If you are already trading GB to NI: The main changes are now in effect. Ensure you have UKIMS authorisation if you need it, and that your "Not for EU" labelling is compliant for any food products.

If you are planning to start trading GB to NI: Register for the Trader Support Service first (it is free and provides guidance). Then apply for UKIMS if your business model requires it.

Watch for July 2025: This is when Phase 3 "Not for EU" labelling comes into force for remaining product categories, and NIRMS checks reduce to 5%.

Getting help

The Windsor Framework is complex, and HMRC provides free support through the Trader Support Service.

What the Trader Support Service offers

The Trader Support Service is a government-funded service that provides:

• Free training and education on Windsor Framework requirements
• Guidance on which schemes and authorisations you need
• Customs declaration services (they can submit declarations on your behalf)
• Help with entry summary declarations under ICS2

For most small businesses starting out with GB-NI trade, registering with the Trader Support Service is the best first step. They can help you navigate the requirements without you needing to become an expert in customs procedures.

Other sources of help

Beyond the Trader Support Service:

• GOV.UK Windsor Framework collection - Official guidance and publications
• Your trade association - Sector-specific guidance and peer support
• Customs agents - Can handle declarations for you (fee-based)
• HMRC webinars - Regular free sessions on specific topics