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Trade with Northern Ireland: RULE EXPLAINER: What applies when and how to prepare

A BIG WEEK for the Northern Ireland Protocol: the new UK Internal Market Scheme kicked in on 30 September 2023 and the Northern Ireland Retail Movement Scheme on 1 October 2023. We look at how trade between Great Britain and Northern Ireland will work.

On February 27 2023, the UK and EU signed the Windsor Framework, a new collection of agreements to

  • improve the UK internal market,

  • secure Northern Ireland's access to the EU Single Market,

  • solve the perceived democratic deficit at the core of the original Northern Ireland Protocol.

Watch Our Explainer Video on the Windsor Framework

What's the law? Meet the The Customs (Northern Ireland) (EU Exit) Regulations 2023

There are quite a few that apply, but this one is particualry relevant in the context of Northern Ireland: The Customs (Northern Ireland) (EU Exit) Regulations 2023

Understand the Customs (Northern Ireland) (EU Exit) Regulations 2023, download the latest legal Notices, and get the latest updates.

But how will it work in practice, and what are the key arrangements?

Let's take a look. But the critical question is, at this point, NOT really...

  • WHAT is changing (as most is just extended) but

  • WHEN it is changing.

This is because some provisions are already in operation and some are not. So, first, we need to understand what applies before knowing what we should do about it.

In other words, to provide companies enough time to adjust to new arrangements, the Framework will be implemented in phases until 2025.

What's already in operation

  • Northern Ireland now implements a temporary VAT zero-rate for household solar panels, insulation, heat pumps, and other energy-saving products. The Protocol had previously prevented this relief, but it has been available in the rest of the UK since 2022.

  • A long-term program supports importing and selling secondhand UK cars in Northern Ireland.

  • The UK also reimburses EU duty on "at risk" products used or sold outside the EU from June 30, 2023.

TOP TIP: If you have any questions regarding the Northern Ireland Protocol, the Windsor Framework or how to move goods between Northern Ireland and Great Britain, please book a free call at -> Book expert call.

In a way, a key part of the agreement is the intriguing concept of "Green Lanes" and "Red Lanes," which provide UK companies exporting to Northern Ireland a faster route but are not without challenges. The Green Lane presents the most tempting prospect for UK businesses. It permits the easy import of goods from the UK into Northern Ireland without paying additional taxes or customs. Paperwork is hardly required and customs inspections are reduced as much as possible (some say eliminated).

But to get there, businesses must follow a step-by-step approach, starting with the UK Internal Market Scheme.

30. September 2023: UK Internal Market Scheme IS A MUST FOR EASIER TRADE

The UK Internal Market Scheme is a pre-requisite granted the importer permission to utilize the Green Lane (see below) later. To join the UK Internal Market Scheme, you must apply online to get authorized. Once authorized, you can declare your goods ‘not at risk’ if they are brought into Northern Ireland for sale or final use by end consumers in Northern Ireland (and Great Britain in the case of movements from Great Britain).

We can help you apply for the UK Internal Market Scheme. Please get in touch and book a free call at -> Book Expert Call

1 October 2023: Northern Ireland Retail Movement Scheme

The Northern Ireland Retail Movement Scheme, is a programme specifically for packaged food. This programme mandates that all food from the UK that is sold to customers in Northern Ireland adhere to UK Public Health Authority guidelines. This program includes "Not for EU" labelling regulations for specific foods, which will be implemented throughout the UK by 2025.

Food sold to end customers in Northern Ireland (NI) won't need to comply with EU import regulations like Export Health Certification (EHCs), and 'third country' restricted commodities like chilled meats from GB suppliers can still be marketed.

1 October 2024: Green or Red lane - I am confused...explain

In a way, a key part of the agreement is the intriguing concept of "Green Lanes" and "Red Lanes," which provide UK companies exporting to Northern Ireland a faster route but are not without challenges.

Green Lane: Open Road if you meet conditions.

In the simplest terms possible, the so-called "Green Lane" related to the flow of products from Great Britain to Northern Ireland of any origin determined to be "NOT AT RISK" of entering the EU Single Market and will remain in Northern Ireland. However, this regulation does not go into effect until 01/10/24.

‘Not at risk’ goods will:

  • not be charged duty if entering Northern Ireland from free circulation in Great Britain (England, Scotland and Wales)

  • be charged UK duty if entering Northern Ireland from outside the EU and the UK

  • be charged UK duty if entering Northern Ireland from Great Britain and the goods were not in free circulation in Great Britain

Red Lane: Costs and bureaucracy

Red Lane is for consignments that are "at risk," so it must continue to abide by EU import regulations, including tariffs and import declarations where necessary. This situation has existed from January 1, 21. These goods must undergo a rigorous customs check, which calls for additional documentation and associated costs. There is a significant problem when goods intended for Northern Ireland wind up in the Republic of Ireland. In this case, businesses are being scrutinized, and questions of compliance and accountability are brought up.

‘At risk’ goods will be charged the applicable EU duty.

What should businesses do trading with Northern Ireland from Great Britain?

  1. Learn about the unique situation of Northern Ireland. We run monthly training on Northern Ireland trade; please book at

  2. Arrange for customs clearance, please contact us as we offer brokerage services and can move your product to and from Northern Ireland with ease.

  3. Apply for the UK Internal Market Scheme to prepare for trading on the Green Lane

More information and Updates

Our collections of updates on Northern Ireland Trade

For the latest news read our collection of updates on Northern Ireland:

Advice & Support

As a trade consultant that advises clients in Northern Ireland, Great Britain, and the European Union on trading in, to, and from Northern Ireland, we are delighted to give some background for individuals who may not be aware of the various trade arrangements that are in place in this region of the United Kingdom since I understand how complex it can be for those who are not familiar with these arrangements. Please get in touch and book a call at -> Book Expert Call


Course: Northern Ireland - Successful GB-NI-ROI (EU) Trade

This course develops the competencies that professionals need to deal with all aspects of the trade in goods with Northern Ireland, including understanding the rules laid out by the Ireland/Northern Ireland Protocol, and practical processes and procedures. (Course ID: E-FA 07)


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