Windsor Framework — Shipping Goods to Northern Ireland (UKIMS)

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What is the Windsor Framework and how did it change the Northern Ireland Protocol?

The Windsor Framework is an agreement between the United Kingdom and the European Union — agreed politically on 27 February 2023 and formally adopted by a Joint Committee decision of 24 March 2023 — which amended and re-implemented the Protocol on Ireland and Northern Ireland (the Protocol remains in force, in an amended form). Its aim was to reduce the number of checks and formalities when goods move from Great Britain (England, Scotland, Wales) to Northern Ireland, while preserving the integrity of the EU single market for goods that actually continue to the Republic of Ireland or other EU countries.

In practice the Windsor Framework introduced two separate routes for goods moving from Great Britain to Northern Ireland (described in 2023 as the “green lane” and “red lane”; current GOV.UK guidance, applicable from 1 May 2025, uses the terms UKIMS and “not at risk” and “at risk” goods):

• “Not at risk” goods (simplified route) — for goods that remain in the United Kingdom (Northern Ireland is part of the UK), are intended for sale or final use in the UK, and meet the other conditions described below.
• “At risk” goods (full formalities) — for goods considered to be at risk of onward movement into the European Union, or that do not meet the conditions of the simplified route.

For Polish businesses trading with Northern Ireland, the key point is that these simplifications apply to movements within the United Kingdom (Great Britain → Northern Ireland). The movement of goods directly between the EU and Northern Ireland looks completely different: Northern Ireland applies the EU Customs Code for goods, so a consignment travelling directly from Poland to Northern Ireland (and back) does not require customs declarations — it is treated like an intra-EU movement (GOV.UK: “Declarations are not needed for any goods moving directly from Northern Ireland to the EU”; the same applies in the EU→NI direction). The standard UK–EU import and export rules (customs declarations, ENS, GVMS) apply only to consignments to and from Great Britain (England, Scotland, Wales).

“Not at risk” goods — the simplified route and who can use it

The simplified route allows goods to move from Great Britain to Northern Ireland without a full customs declaration, on the basis of a simplified data set instead of a standard import declaration. Access is not automatic — it requires authorisation under the UK Internal Market Scheme (UKIMS), which replaced the earlier UK Trader Scheme on 30 September 2023.

Conditions for UKIMS authorisation

According to the official GOV.UK guidance, to obtain UKIMS authorisation a business must be established in the United Kingdom, and must meet all of the following conditions:

• have a good record of customs and tax compliance,
• have no serious criminal offences connected with its business activity,
• demonstrate sound financial standing — including no insolvency proceedings and settled customs and tax liabilities over the last 3 years,
• demonstrate a clear understanding of the obligations under the scheme.

A business that moves goods from Great Britain and has no permanent place of business in Northern Ireland must additionally have an indirect customs representative in Northern Ireland (for example under the free Trader Support Service) and ensure that its documentation is available in the UK. There is no requirement to have a permanent place of business in Northern Ireland.

What must be declared instead of a full customs declaration

Instead of a standard import declaration, an authorised trader provides Internal Market Movement Information (IMMI) — a simplified data set based on commercial information. For B2B consignments GOV.UK indicates, among other things, the following data: the UKIMS authorisation number and EORI number, the details of the consignor and consignee in Northern Ireland, the value of the consignment and — at item level — the description of the goods, the commodity code and the quantity. The trader must also confirm that the goods meet the “not at risk” conditions and keep evidence of that status for 5 years.

“Not at risk” status does not come from a single definition but from meeting several conditions together, including: the goods are intended for sale or final use in the UK, they are moved directly from Great Britain to Northern Ireland, they are moved by a business authorised under UKIMS, and they will not be placed under a special procedure (for example customs duty suspension) and are not Category 1 goods. If any condition is not met, the goods are “at risk”.

An additional tool supporting declarations is the Trader Goods Profile (a database that helps traders complete goods data), as well as the option to account for goods using Entry in Declarant's Records (EIDR) under a UKIMS authorisation.

“At risk” goods — when goods are subject to full customs clearance

Goods that do not meet the conditions of the simplified route must go through the full customs procedure — with a complete import declaration and, if the goods are considered to be at risk of onward movement to the EU, with the EU rate of duty applied instead of the UK rate.

Three categories of goods in the GB–NI categorisation system

The official GOV.UK classification divides goods moving from Great Britain to Northern Ireland into three groups:

• Standard goods — eligible for simplified processes, declared on the basis of a 6-digit commodity code, provided that the “not at risk” criterion is met.
• Category 2 — also eligible for simplifications, but requiring an 8-digit commodity code and additional documentation (certificates, authorisations, net mass data). It covers, among other things, goods subject to excise, sanitary, licensing or environmental controls — including cigarettes and some agri-food products (subject to the separate NIRMS scheme, see below).
• Category 1 — goods that are not eligible for simplified processes. It covers goods subject to restrictions under Article 215 of the Treaty on the Functioning of the European Union, outright bans or import prohibitions, trade defence measures, and goods subject to EU tariff rate quotas and non-tariff quotas.

Regardless of category, the simplifications also exclude, among others, goods placed under customs duty suspension, goods benefiting from customs, excise or VAT reliefs on release for free circulation, and goods actually intended for onward export to the EU.

A business can check the category of its goods using the Northern Ireland Online Tariff, its own customs software, the Trader Goods Profile or via the Trader Support Service.

Food and agri-food products — NIRMS and the announced SPS agreement

For the movement of retail-packaged agri-food products from Great Britain to Northern Ireland, the Windsor Framework provides a separate mechanism — the Northern Ireland Retail Movement Scheme (NIRMS), which replaces some of the standard sanitary and phytosanitary checks required for ordinary food imports.

It is worth distinguishing NIRMS (an already operating GB–NI mechanism under the Windsor Framework) from the broader, only announced UK–EU sanitary and phytosanitary agreement (the SPS agreement), which would cover all food trade between Great Britain and the European Union, not just movements within the UK. We have described the details of this announcement and its current legal status in the article UK–EU SPS agreement and food exports.

GB or XI EORI — does it matter when trading with Northern Ireland?

An EORI number with the XI prefix is assigned to businesses registered and operating in Northern Ireland, whereas an EORI with the GB prefix relates to activity in Great Britain. For UKIMS authorisation and IMMI declarations, which EORI number the consignor and consignee use has real operational significance — the treatment differs depending on where the business is actually established. A full explanation of when the GB/XI difference really affects clearance can be found in the article GB or XI EORI – when the difference really matters.

The most common mistakes made by businesses exporting to Northern Ireland

• Treating Northern Ireland like the rest of Great Britain — a shipment from Poland directly to Northern Ireland does not require a customs declaration (NI applies EU customs rules for goods), and UKIMS procedures apply only to GB→NI movements. UK–EU export and import declarations apply only to Great Britain.
• Assuming that “not at risk” status applies automatically — without UKIMS authorisation, without meeting all the conditions and without evidence that the goods are intended for the UK market, the goods are treated as “at risk”.
• Neglecting record retention — GOV.UK requires evidence supporting each “not at risk” movement to be kept for 5 years.
• Incorrect categorisation of goods — confusing standard goods with Category 1 or 2 leads to an incorrect declaration and the risk of EU duty being charged afterwards.
• Extending individual GOV.UK notices (for example those on specific categories of goods) to the entire UK market without checking whether the change actually applies only to Northern Ireland — we described an example of this trap in connection with the export notice for sensitive goods in the article ECJU Notice 24: extended controls on goods that could be used for capital punishment and torture.

If your business plans regular trade with Northern Ireland and you want to check whether your goods qualify for the simplified “not at risk” route and which documents will be needed, contact us — we will help you establish the right procedure.

Sources

• GOV.UK — Apply for authorisation for the UK Internal Market Scheme (UKIMS)
• GOV.UK — Internal market movements from Great Britain to Northern Ireland
• GOV.UK — Categorising goods for internal market movements from Great Britain to Northern Ireland
• GOV.UK — Fact sheet: Business-to-business parcel movements under the Windsor Framework
• GOV.UK — Moving goods into, out of, or through Northern Ireland (guidance collection)

Frequently asked questions