The Windsor Framework Explained: Trading Into Northern Ireland

What Is the Windsor Framework?

Agreed in February 2023 and operational from October 2023, the Windsor Framework is the UK–EU agreement that governs how goods move from Great Britain into Northern Ireland. It replaced the most disruptive elements of the original Northern Ireland Protocol with a two-lane system designed to keep internal UK trade flowing while protecting the EU's single market.

For businesses sending goods from GB to NI, this is the rulebook that matters.

The Green Lane vs the Red Lane

Goods moving from GB to NI now travel in one of two lanes:

Green Lane — "Not at risk" of entering the EU

Goods destined to stay in Northern Ireland (sold to NI consumers, used by NI businesses) move in the green lane. These benefit from:

No EU customs duty (regardless of origin)
Simplified declarations — minimal data, often pre-loaded by the trader's authorised representative
No routine physical checks at the port

To use the green lane, traders must be authorised under the UK Internal Market Scheme (UKIMS) — a scheme HMRC operates for established businesses with a presence in the UK.

Red Lane — "At risk" of entering the EU

Goods that might be re-exported into the Republic of Ireland (and therefore the EU) travel in the red lane:

Full EU customs declaration required
EU duties payable if applicable
Checks per EU rules (especially for agri-food)

Goods are also placed in the red lane if the trader is not UKIMS-authorised, or if the goods are subject to specific commercial agreements involving onward EU movement.

What About Agri-Food?

Agri-food goods have their own track under the Windsor Framework: the Northern Ireland Retail Movement Scheme (NIRMS). Pre-packed retail goods moving to NI supermarkets follow simplified rules — including a single "Not for EU" label — and benefit from reduced inspection rates compared to standard EU import controls.

The Trader Support Service (TSS)

The UK government funds a free service — the Trader Support Service — that handles all customs declarations for GB ↔ NI movements on behalf of traders. TSS prepares:

The Entry Summary Declaration (ENS)
The Simplified Frontier Declaration (SFD) for green-lane movements
The Supplementary Declaration filed afterwards

If you are an established trader, you'll typically be UKIMS-authorised and route via TSS. We work with TSS on your behalf so you don't have to learn its system.

What Does This Mean for Irish Businesses?

For traders based in the Republic of Ireland, the Windsor Framework matters less directly — ROI → NI movements stay inside the EU and don't trigger customs. But:

GB → NI via Ireland routing can be affected if you're handling the GB origin leg
NI → GB movements are generally unfettered, since NI goods can move into GB market freely under the UK Internal Market Act
GB exporters with NI customers need UKIMS authorisation to send goods in the green lane

How We Help

We register clients for UKIMS, prepare TSS-based declarations for green-lane movements, and handle full red-lane EU import procedures when those are required. For agri-food clients, we navigate the NIRMS pre-packed retail scheme and ensure label compliance.