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NI-GB trade: How the border in the Irish Sea works

Businesses with NI trade need to understand the Withdrawal Agreement between the EU and the UK to accelerate IE-NI-GB trade movements. Let's clarify.


For years, we knew that Northern Ireland will remain in the UK customs union but was required to apply the EU customs rules, known as the Union Customs Code (UCC) and quite a few laws under the EU Single Market, to ensure the border with the Republic of Ireland (ROI) remains "soft" or "open".

Many months of negotiations behind closed doors finally produced several agreements through the "Joint Committee" of the UK-EU (see below for the formal decisions taken). This formally completes the work on how the "Withdrawal Agreement" (WA) with its "Protocol of Northern Ireland and Ireland" will actually work in practice.


Trading with Northern Ireland: A discussion of customs and global trade specialists

Lesley Batchelor and Arne Mielken discuss how trading with NI works.


In one sentence: What's in it?

The agreement includes for the direction GB to NI:

  1. grace periods for agri-food products from requiring traders to hold valid export health certificates

  2. no check for chilled meats from at ports,

  3. gradual phasing in of the EU's medicines' regulations.

'Finally, clarity on which products are deemed "at-risk"

The Joint Committee has decided on two important aspects to define goods at risk. These apply even though there is a trade deal between the EU and the UK.

  1. NI businesses need prior authorization. A new authorized Trader Scheme will allow companies to apply for a status of "goods not at risk". This means that their products are not deemed to be at risk of being forwarded to RoI and, therefore, the EU. Being authorized is significant: These businesses will not have to pay EU tariffs for the authorized movement. No authorization means that duties will potentially become due.

  2. GB businesses can have this authorization, too! The approval is also available for businesses outside in GB where they meet several "closely linked criteria’" to a company that is established in Northern Ireland, such as

    1. who does this company sell goods too?

    2. What is the final end-use?

    3. Where are the final consumers located?

NI -GB: What happened to the "unfettered access policy?"

The UK has specifically noted

  • Northern Ireland’s place in the United Kingdom’s customs territory,

  • the need to protect the Belfast (Good Friday) Agreement in all its

  • dimensions,

  • and its commitment to unfettered access for Northern Ireland businesses to the whole of the UK market.

Overall, export declarations will, therefore, NOT be required for Northern Ireland businesses to move their products to Great Britain - following the unfettered access policy of the UK government.

Irish or EU products to Great Britain

No customs declaration, too, right? No luck, I am afraid.

"The United Kingdom confirms its intention that standard export procedures will apply where goods:

  1. are placed under a procedure listed in Article 210 of Regulation (EU) No 952/2013,

  2. are in temporary storage in accordance with Article 144 of that Regulation,

  3. are subject to provisions of Union law falling within the second sentence of Article 6(1) of the Protocol which prohibits or restrict the exportation of goods,

  4. are placed under the export procedure within the Union, o

  5. do not exceed EUR 3000 in value and are packed or loaded for export shipment within the Union".

In the other word, where goods move from the EU to GB via NI and where goods move in duty suspension or have been placed under the export procedure, export declarations will be needed and enforced by the UK's HMRC. We will discuss this more in our webinar on Wednesday.

14 specific areas for export declarations in NI to GB trade

There are fourteen instances where these declarations may nonetheless be needed, even for NI-GB trade. This is mainly in relation to international treaty obligations, such as rough diamond trade or endangered species trade. These are probably very rarely traded from NI to GB.

The most significant impact of these declarations will be felt in relation to IE - > GB trade via NI, where a declaration is needed.

Free Export Health Certificates

Export Health Certificates are needed for certain products of animal origin, plants and grain, known as sanitary and phytosanitary products. These certificates are needed to ensure food safety and animal and plant health. The certificates make sure that what NI and EU consumers is safe to eat. Yet until the end of March 2021, no approvals of this kind is needed for all so-called "SPS trade". The "grace period" is extended to six months for bringing goods from GB into NI supermarkets and convenience stores. Chilled meats coming from GB will also not need such a certificate until July 2021. For all others, the so-called "Movement Assistance Scheme (MAS)," will be introduced shortly to pay for the costs associated with getting these certificates.


The Northern Ireland Approach Paper of D
Download • 217KB
Goods Not At Risk - Draft Decision Paper
Download • 119KB
Export Declarations - UK Statement
Download PDF • 37KB


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