Understand the Windsor Framework

Complete guide to GB-NI trade requirements including UKIMS, NIRMS, EORI numbers, green/red lanes, duties, and VAT.

Key schemes explained

The Windsor Framework creates simplified routes for most GB to NI goods movements. Understanding which schemes apply to your business is the first step.

The Windsor Framework (effective from 2023) governs the movement of goods between Great Britain and Northern Ireland, creating a dual regulatory system where NI remains in the UK customs territory while following certain EU single market rules for goods.

UK Internal Market lane: Simplified route for goods staying in Northern Ireland - no customs declarations required
Red lane: For goods at risk of entering EU single market - full customs requirements apply
Coverage: Approximately 97% of goods expected to use UK Internal Market lane
Full implementation: 1 May 2025 - full arrangements in place

Windsor Framework guidance (opens in a new tab)

Get your EORI number

All businesses making customs declarations need an EORI (Economic Operators Registration and Identification) number. NI businesses typically need both GB and XI EORI numbers.

XI EORI requirement: Required for moving goods into NI from GB or to non-EU countries
GB EORI first: Must obtain GB EORI before applying for XI EORI
GB EORI processing time: Immediate (or up to 5 working days if checks required)
XI EORI processing time: Within 5 working days after obtaining GB EORI
Proof of NI establishment: 2 documents required (e.g. bank statement, utility bill)
Proof exemption: Not required if GB EORI address is in NI or solely for declarations/carrier activities
Application cost: Free
Effective from: 1 January 2021

UKIMS eligibility

UKIMS is for businesses moving goods intended for the NI market (not for onward movement to the EU). You must meet eligibility requirements and keep records.

Establishment requirement: Must be established in the UK
NI-based businesses: Need permanent premises with human/technical resources in NI
GB-based businesses: Need indirect customs representation (e.g. Trader Support Service)
Compliance record: Good customs and tax compliance for previous 3 years
Criminal record check: No serious criminal offences related to economic activity
Financial standing: No bankruptcy proceedings
Record keeping: Commercial receipts, invoices, delivery receipts, consignment notes
Evidence requirement: Must demonstrate goods for final consumption in UK

NIRMS for food products

NIRMS provides simplified arrangements for prepacked retail food moving from GB to NI. You must register separately and apply 'Not for EU' labelling.

Scheme purpose: Simplified movement of prepacked retail agrifood goods GB to NI
Replaces: Scheme for Temporary Agrifood Movements into Northern Ireland (STAMNI)
Effective from: 1 October 2023
Registration requirement: Both sender (GB) and receiver (NI) must be registered
Registration method: Online via Export Health Certificate Online (EHC Online)
Documentation: Single General Certificate per consignment (replaces individual export health certificates)
Contact email: NIRetailMovementEnquiries@apha.gov.uk
Contact phone: 03000 200 301 (Mon-Fri, 8:30am-5pm)

'Not for EU' labelling phases

Goods moving under NIRMS must carry special labelling to show they're for NI consumption only. Requirements are being phased in.

Label requirement: Must display 'Not for EU' - clearly visible, non-removable
Phase 1 (1 October 2023): Meat and selected dairy products
Phase 2 (1 October 2024): All milk and dairy products
Phase 3 (1 July 2025): Composite products, fish, eggs, fruit/vegetables, honey
Grace period: 30 days after each phase launch for existing inventory

Green lane vs red lane

Goods are routed through different lanes at the border depending on their final destination and risk of entering the EU market.

UK Internal Market lane (green): For goods staying in NI - simplified requirements, no customs declarations
Red lane: For goods at risk of moving to EU - full customs declarations and checks
At risk goods: Goods intended for or likely to enter EU single market
Not at risk goods: Goods for NI consumption with UKIMS or NIRMS authorisation
Green lane checks: Reduced to 5% of consignments from 1 July 2025

Internal market movements from GB to NI (opens in a new tab)

Duty reimbursement

Claim back EU duty if your goods were charged as 'at risk' but remained in NI for consumption rather than moving to the EU.

Scheme launched: 30 June 2023
GB to NI claim amount: Full duty amount claimable
Outside UK/EU to NI: Difference between EU duty and UK duty (if EU duty higher)
Claim deadline (2021-2023): By 30 June 2026 for goods moved 1 January 2021 to 30 June 2023
Claim deadline (after June 2023): Within 3 years of duty notification
Bulk claim limit: Maximum 250 consignments per bulk claim
Bulk claim restriction: All movements must share same reimbursement condition

VAT for NI trade

NI follows UK VAT rules for goods but has a unique position for EU trade. GB to NI sales are treated as domestic - charge standard UK VAT.

VAT rules: UK VAT rules apply in NI (with some EU exceptions for goods)
VAT registration threshold (2026-27): £90,000 - same across UK
EU small business VAT scheme: Does NOT apply in NI
XI VAT number: Required for NI businesses supplying goods to/from EU
Energy-saving materials: Zero VAT rate applies in NI (aligned with GB)
Excise duties: UK excise rates apply throughout NI

VAT and Northern Ireland (opens in a new tab)

Sending parcels to NI

Simplified rules apply for parcels. Consumer deliveries require no customs declarations - carriers handle compliance under the UK Carrier Scheme.

B2C parcels (to consumers): No customs declarations required
B2C data sharing: Carrier shares standard commercial data with HMRC instead
B2B parcels (business to business): All B2B parcels require CDS submission
B2B submission: Carrier may submit as part of door-to-door service
Low value threshold: 135 pounds - no UKIMS required for 'not at risk' goods below this
UKIMS requirement: Either sender or receiver must be UKIMS authorised for simplified process
Effective from: 1 May 2025

Trader Support Service

Government-funded service offering free support for businesses trading between GB and NI, including training and declaration assistance.

Service type: Free customs declaration service for GB-NI movements
Cost: Free
Services provided: Education, training, advice on Windsor Framework; customs and safety/security declarations
Entry summary declarations: TSS can submit on your behalf
ICS2 registration: Not needed for TSS users
Registration: Online at tradersupportservice.co.uk

Implementation timeline

The Windsor Framework is being implemented in phases. Key dates affect when requirements come into force and deadlines for registration.

Framework announced: 27 February 2023
Formally adopted: 24 March 2023
Duty Reimbursement Scheme: 30 June 2023
UKIMS replaces UKTS: 30 September 2023
Windsor Framework effective: 1 October 2023
NIRMS launched: 1 October 2023
Duty Waiver limit increased: 1 January 2024
Full green lane: 30 September 2024
ICS2 mandatory: 1 April 2025
New parcel arrangements: 1 May 2025
NIRMS Phase 3 labelling: 1 July 2025
ICS2 transition complete: 1 September 2025

Export goods from the UK

General export requirements, customs declarations, and documentation for selling internationally.

Import goods to the UK

Import procedures, duties, and VAT for bringing goods into Great Britain from outside the UK.

Trading with Northern Ireland

Understand the Windsor Framework

Export goods from the UK

Import goods to the UK

Related journeys

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Windsor Framework: quick compliance check for GB businesses

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