The implementation of the Framework will happen in stages through into 2025, to provide businesses with time to adapt to the new trading arrangements.

Windsor Framework - A timeline

The following is a timeline of some key dates regarding the implementation of the Windsor Framework that may impact businesses in either Northern Ireland or Ireland:

01 October 2023: The UK Internal Market Scheme launches and replaces the existing UK Trader Scheme. Note: Businesses who are eligible for this scheme must register, even if previously registered for the UK Trader Scheme.

01 October 2023: The Retail Movement Scheme for prepackaged retail goods of plant and animal origin is launched. This will also include the phased introduction of new labelling requirements on certain products imported into Northern Ireland from Great Britain.

01 January 2024: Expansion of the customs duty waiver scheme with the limit for Northern Ireland businesses increasing from €200,000 to €275,000 over a three-year period.

31 January 2024: Beginning of the phased introduction of the Border Target Operating Model (BTOM) this will be particularly impactful for businesses in Ireland who are exporting medium risk plant and animal-based products to GB.

01 October 2024: Introduction of Phase 2 labelling requirements when using the Retail Movement Scheme. This includes a requirement for individual labelling on all milk and dairy products being imported into Northern Ireland.

01 January 2025: New rules covering the import of medicines into Northern Ireland will be introduced.

1 May 2025: Full introduction of the new Red / UK Internal Market lanes. From these dates businesses importing via the UK Internal Market lane will no longer be required to complete supplementary declarations for goods movements into Northern Ireland.

1 May 2025: Introduction of new requirements on parcel movements from Great Britain to Northern Ireland.

01 July 2025: Introduction of all remaining labelling requirements on goods imported into Northern Ireland through the Retail Movement Scheme. This is sometimes referred to as Phase 3 requirements.

01 July 2025: SPS Facilities are to be in place in Northern Ireland.

31 December 2025: Grace Period for Veterinary medicines ends. UK must ensure that supplies of veterinary medicines confirm to relevant EU Law.

What are UK Internal Market lanes?

As part of the Windsor Framework the UK and the EU have agreed on the introduction of a red lane and a UK Internal Market lane for goods entering Northern Ireland. Simply put the UK Internal Market lane is a term used to explain the level of customs processes that will be required upon import into Northern Ireland.

Due to a phased implementation approach of the Framework, the full "UK Internal Market lane" will take effect from May 2025 for the movement of all goods between Great Britain and Northern Ireland, though businesses registered for the UK Internal Market Scheme (UKIMS) can now take advantage of the new expanded criteria for declaring goods as "Not At Risk".

From 1 May 2025, UKIMS authorised traders will be able to benefit from providing the simplified data set to move goods through the "UK Internal Market lane". This will allow traders to provide a reduced dataset of information to HMRC rather than a more complicated supplementary declaration.

What are Red Lanes?

As with UK Internal Market lanes, a red lane is a term used to describe the level of customs processes required upon import into Northern Ireland. Any goods which enter Northern Ireland from the rest of the UK which are bound for the EU including Ireland, or any goods which are deemed to be "At Risk" of entering the EU, will enter via the red lane.

When goods travel through the red lane full EU customs checks, paperwork and controls will apply, also including the payment of tariffs. Businesses that move goods through the red lane but whose goods do not subsequently enter the EU will be able to make use of the Duty Reimbursement Scheme that will allow traders to reclaim EU duty paid on goods that can be shown not to have entered the EU.

What does declaring goods "At Risk" mean?

Any goods which are "At Risk" will be required to follow the red lane model. As a result, they will be required to comply with full EU customs requirements including customs declarations upon entry into Northern Ireland.

Can I still use the Trader Support Service?

As a core part of the Windsor Framework arrangements, the government will continue to provide a free-to-use support service for those moving goods between Great Britain and Northern Ireland. If you are not already registered for the Trader Support Service, you can do so via the following link: Trader Support Service.

What is the "Stormont Brake"?

The Windsor Framework includes a new safeguard which is referred to as the Stormont Brake. The Stormont Brake allows the Northern Ireland Assembly to veto changes in EU laws that apply in Northern Ireland if these changes are expected to cause a significant impact on everyday life.

What does the Windsor Framework mean for parcel movements from GB to NI?

From 1 May 2025, a new set of arrangements for the movement of parcels under the Windsor Framework will apply, which provides a durable basis on which to enable consumers to send and receive parcels as they do today, alongside parcel operators sharing standard commercial data with HMRC. As of that point, the same "UK Internal Market lane" arrangements that are applied for freight movements will also apply for parcel consignments moved between businesses.

Find out more in our Trade Hub article Understanding customs changes when moving parcels into Northern Ireland.

What does the Windsor Framework change for VAT and excise?

Under the Northern Ireland Protocol, Northern Ireland is subject to EU VAT and excise rules in relation to goods. The Windsor Framework amends the legal text of the protocol to ensure that Northern Ireland will be subject to the same VAT and excise rules that apply in the rest of the UK. This will allow NI businesses to apply zero rates of VAT, in particular, the current 5% rate of VAT being applied in NI on energy-saving materials (solar panels and heat pumps) has been reduced to 0% from to align with the rest of the UK. Find out more on GOV.UK - Energy-saving materials and heating equipment (VAT Notice 708/6).

UK Internal Market Scheme

The UK Internal Market Scheme is now open for registration and has replaced the UK Trader Scheme. The UK Internal Market Scheme allows registered traders to declare goods "not at risk" if they are imported into Northern Ireland for sale or final use within the UK.

From 1 May 2025, registered businesses will be able to avail of simplified declaration requirements which will remove the need for supplementary customs declarations on goods deemed "Not At Risk" upon entry into Northern Ireland. Under these new simplified processes only existing commercial information will be required.

Find out more about the UK Internal Market Scheme including eligibility requirements and how to apply in this Trade Hub article: Red and UK Internal Market lanes FAQs.

Duty Reimbursement Scheme

The UK government has recently launched a Duty Reimbursement Scheme. The purpose of this scheme is to enable businesses to reclaim duty which has been paid on goods which were initially deemed to be “At Risk” but which were subsequently found to have remained in Northern Ireland.

Find out more in this Trade Hub article: Duty Reimbursement Scheme.

Will I still be able to avail of the Customs Duty Waiver Scheme?

Going forward businesses importing goods from Great Britain to Northern Ireland will continue to be able to avail of the Customs Duty Waiver Scheme. Businesses in Northern Ireland can claim up to €300,000 over three tax years through the customs duty waiver scheme.

Find out more in this Trade Hub article: Customs Duty Waiver and de minimis Aid.

Sanitary and Phytosanitary

The Windsor Framework sets out dedicated arrangements to support the critical flow of agri-food retail products into Northern Ireland. These movements were previously supported under the Scheme for Temporary Agri-food Movements to Northern Ireland (STAMNI). This has now been replaced by a new scheme called the Retail Movement Scheme.

The Retail Movement Scheme enables a much broader range of traders to move prepackaged retail goods into Northern Ireland with a single general certificate, reducing the volume of paperwork, checks and certification requirements.

Find out more in our Trade Hub articles about:

Retail Movement Scheme

Labelling requirements associated with the Retail Movement Scheme.

Article reviewed by the Trade Hub team: March 2025