The Northern Ireland Protocol, agreed between the UK and EU as part of the Brexit withdrawal arrangements, set up a unique status for Northern Ireland: aligned with EU customs and VAT rules for goods, but inside the UK customs territory and VAT system. The Windsor Framework, agreed in February 2023 and implemented in stages, replaced the most contested elements of the Protocol with a "green lane / red lane" approach for goods moving from Great Britain to Northern Ireland. Two years into the Windsor Framework, the rules are settling, but practical questions still come up regularly.
The basic position
Northern Ireland is part of the UK customs territory and UK VAT area but follows EU rules for goods. A NI business buying goods from another EU member state treats it as an EU acquisition, not an import. A NI business selling goods to an EU customer treats it as an EU dispatch. NI businesses use an XI EORI for movements to and from the EU, alongside a GB EORI for movements involving Great Britain.
Goods moving from Great Britain to Northern Ireland are technically "internal UK movements" but, because Northern Ireland follows EU rules for goods, the movement carries some EU-style checks. The Windsor Framework redesigned how those checks operate.
The green lane and the red lane
Under the Windsor Framework, goods moving from Great Britain to Northern Ireland that are destined for Northern Ireland use (not onward movement to the EU) move via the green lane. Green-lane goods face minimal checks and use a simplified customs declaration through the UK Internal Market Scheme (UKIMS). Traders must register under UKIMS, meet eligibility criteria, and use registered hauliers.
Goods moving from Great Britain to Northern Ireland that are at risk of moving onward to the EU use the red lane. Red-lane goods follow full EU import procedures, with declarations, duty (where applicable), and any other EU requirements such as sanitary and phytosanitary controls.
UK Internal Market Scheme (UKIMS)
UKIMS is the registration scheme that lets eligible traders move goods via the green lane. To register, a business must meet conditions including being established in the UK, having a track record of customs compliance, and committing to keep records that allow HMRC to verify that goods are not moving on to the EU.
The UKIMS scheme replaced and broadened the earlier UK Trader Scheme. Eligibility is wider, and a larger number of businesses now qualify. For a business moving regular consignments of goods to Northern Ireland customers, UKIMS registration is essentially essential.
VAT on goods to and from Northern Ireland
VAT on goods movements between Great Britain and Northern Ireland is treated as internal UK VAT. There is no border, no import VAT, and no customs duty on goods staying in NI. Sales from a GB-registered business to a NI customer follow normal UK domestic VAT rules.
VAT on goods movements between Northern Ireland and the EU follows EU rules. A NI business acquiring goods from Ireland records it as an EU acquisition and accounts for VAT under the reverse charge in its UK VAT return (with the XI prefix on the VAT number for EU customers).
The parcel arrangements
One of the most visible changes from the Windsor Framework concerns parcels sent from Great Britain to Northern Ireland. Under the previous arrangements, even consumer parcels faced customs formalities. Under the Windsor Framework, parcels sent by businesses to consumers in Northern Ireland use a separate simplified system, with information shared between traders and authorities but no per-parcel declaration for the consumer.
Business-to-business parcels follow the green or red lane logic depending on registration and destination. The change has been most visible for high-street retailers and e-commerce businesses serving NI customers.
The Stormont Brake
The Windsor Framework also introduced the Stormont Brake, a mechanism that lets the Northern Ireland Assembly raise objections to new EU goods rules that would apply in NI. The brake is not relevant to most day-to-day trader compliance but is part of the political settlement and has been used in only narrow circumstances since 2023.
Specific product categories
Some product categories have always been the trickiest under the NI arrangements. Agri-food, plant material, medicines, steel, and certain chemicals each have specific rules. The Windsor Framework reduced or removed some of the most burdensome SPS (sanitary and phytosanitary) checks for retail food going to NI, but the underlying compliance for movements at risk of onward EU sale remains in place.
Medicines were a particular flashpoint and now operate under a UK-wide licensing arrangement with NI patients receiving UK-authorised medicines. Steel imports into NI follow EU safeguard tariff measures unless the importer is UKIMS-registered.
Practical implications for GB-based businesses selling to NI
If you sell to NI businesses or consumers from Great Britain regularly, you should be UKIMS-registered, you should know whether your goods qualify as "not at risk" of moving to the EU, and you should be confident in your record-keeping. If your goods are at risk, your customer in NI may face EU import duty if the customer is also EU-VAT-registered.
How PushDigits supports NI-facing businesses
Our VAT team helps GB businesses register for UKIMS, structure their NI sales, and reconcile cross-border VAT positions. Our business advisory team supports clients setting up NI presences and structuring supply chains that include both GB and NI legs.
If you sell to NI and have not reviewed your compliance since the Windsor Framework came in, book a Windsor Framework review or visit our contact page.