Updated: 15th February 2023
Introduction
The Northern Ireland Protocol (NIP), part of the Brexit Withdrawal Agreement, was designed to prevent a hard border on the island of Ireland while maintaining the integrity of the EU single market. Over time, the Protocol has evolved, and the Windsor Framework, agreed in 2023, introduced updates to simplify trade, reduce bureaucracy, and provide clarity for businesses moving goods between Great Britain (GB) and Northern Ireland (NI).
This guide explains the current rules under the Windsor Framework, the latest customs and trade requirements, and what businesses need to know to stay compliant.
What is the Northern Ireland Protocol?
The Northern Ireland Protocol ensures:
- No hard border between Northern Ireland and the Republic of Ireland
- Northern Ireland effectively remains aligned with EU single market rules for goods
- Customs checks are required on some goods moving from Great Britain to Northern Ireland
Key Challenges Addressed by the Windsor Framework
The Windsor Framework, agreed in February 2023, streamlines trade processes and addresses business concerns from the initial Protocol implementation. Key updates include:
1. Green and Red Lanes
- Green Lane: For goods staying in Northern Ireland — minimal checks and paperwork
- Red Lane: For goods destined for the EU — standard EU customs and regulatory checks
This system simplifies trade for businesses and reduces delays for goods only intended for Northern Ireland.
2. Regulatory Alignment
- Businesses moving goods from GB to NI must comply with EU standards for products entering NI
- Products staying in GB do not need EU compliance, reducing unnecessary bureaucracy
3. VAT and Duty Reliefs
- Duty relief for goods staying in Northern Ireland and not entering the EU
- Simplified VAT rules for businesses using the Green Lane
4. Trader Support and Simplified Procedures
- Digital portals for submitting movement and customs information
- Simplified paperwork reduces administrative burden
Customs and Trade Requirements
1. Registration Requirements
- Businesses must register with the UK Trader Support Service if moving goods from GB to NI
- EU importers moving goods into NI must also comply with EU customs declarations when goods enter the EU
2. Documentation and Record-Keeping
- Maintain records of goods moved through Green and Red Lanes for at least 6 years
- Ensure product classification, origin, and destination are accurately documented
3. Goods Classification and Checks
- Food, medicines, and regulated goods require compliance with EU standards
- Non-regulated goods have reduced checks under the Green Lane
4. Ongoing Monitoring
- The Windsor Framework allows periodic review of the flow of goods, customs procedures, and administrative efficiency
- Businesses should monitor updates via the UK Government and EU guidance portals
Practical Tips for Businesses
- Plan your supply chains — know whether goods go to NI only or into the EU
- Use digital portals — submit customs information efficiently
- Understand VAT and duty reliefs — avoid unnecessary costs
- Stay updated — the Windsor Framework evolves with ongoing UK-EU discussions
- Consult trade experts — ensure correct lane selection and compliance
Conclusion
The Northern Ireland Protocol and Windsor Framework together create a unique trade landscape. Businesses moving goods between GB, NI, and the EU must understand:
- The distinction between Green and Red Lanes
- Compliance with EU standards for goods entering Northern Ireland
- VAT, duty relief, and customs documentation requirements
With careful planning and awareness of the Windsor Framework updates, businesses can reduce delays, minimise costs, and ensure smooth trade across the UK-Ireland border.
