Determining whether your goods are "At Risk" is a critical step when importing into Northern Ireland from Great Britain. Read more to find the guidance you need.
Article Content
- What does “At Risk” mean for my products?
- What happens if Goods are deemed “At Risk”?
- How do I know if my products are "At Risk"?
- What if I can’t meet one of the above options?
- Summary
Determining whether your goods are "At Risk" is a critical step when importing into Northern Ireland from Great Britain.
This status affects whether customs duties will apply, depending on factors like the final destination of goods and trade scheme eligibility. In this guide, we’ll walk through the key questions to ask and the options available to reduce or avoid tariffs. Understanding these criteria helps businesses manage costs and stay compliant with Windsor Framework rules.
What does “At Risk” mean for my products?
Goods are considered “At Risk” if:
- They might be sold or used within the EU after entering Northern Ireland.
- The Trader does not hold sufficient evidence to prove goods will remain in Northern Ireland or return to GB.
What happens if Goods are deemed “At Risk”?
When Goods are deemed “At Risk”, EU Customs duties (tariffs) may apply.
How do I know if my products are "At Risk"?
To identify if you will be required to pay a tariff on imports into Northern Ireland from Great Britain businesses should consider asking the following questions on each item imported:
1. Is the Common External Tariff Rate Zero?
The EU Common External Tariff is the default rate set by the EU for all imports into their customs union. If this rate is zero percent, the goods in question can automatically be declared as being “Not At Risk” irrespective of their end destination and there will be no applicable customs duty to pay upon import into Northern Ireland.
2. Can I use the UK Internal Market Scheme? (UKIMS)
The UK Internal Market Scheme allows registered businesses to declare goods as being "Not At Risk", if they can demonstrate that the goods being imported are going to stay in Northern Ireland/return to Great Britain and are not going to enter Ireland or the EU.
If you have registered for the UK Internal Market Scheme and you can demonstrate that your goods are going to stay in Northern Ireland, you can self-certify that your goods are "Not At Risk" and as a result will not be required to pay any customs duty.
When declaring goods as being "Not At Risk" it is essential that appropriate evidence is retained to illustrate that the goods were correctly declared "Not At Risk".
It is important to note that if you move goods which are subject to commercial processing in Northern Ireland there are additional requirements which will need to be met to use this scheme. You can find more information about these requirements and how to register in our UK Internal Market Scheme article.
Note: Even If you had previously registered for the UK Trader Scheme you will need to register for the UK Internal Market Scheme prior to declaring goods as being "Not At Risk".
Key Tip: Just because your business is registered for the UK Internal Market Scheme does not automatically qualify you to declare every item imported as being "Not At Risk". It is recommended that each item imported is reviewed on a case by case basis to ensure that all eligibility criteria have been met.
3. Claiming Preference under the TCA
If unable to use the UK Internal Market Scheme, businesses may wish to consider claiming preference under the TCA.
In December 2020 the UK/EU announced the signing of the Trade and Cooperation Agreement. This trade agreement set out the future trade relationship between the UK and EU. A key part of this agreement is the ability of goods which meet all relevant rules of origin to trade tariff free between the UK and the EU.
This means that if a business in Northern Ireland is importing an item from GB, for which it can be demonstrated that it is of UK origin, then they will be able to import into Northern Ireland without being required to pay customs duty. This is the case even if the goods are subject to commercial processing or if they will enter Ireland.
Should a business wish to claim preference under the TCA, it is imperative that they retain sufficient proof illustrating that all origin requirements have been met.
Businesses in Ireland who import goods of UK origin from GB can also claim preference to help minimise the impact of customs duty on business operations.
What if I can’t meet one of the above options?
If you cannot meet one of the above options your goods will be subject to customs duty upon entry into Northern Ireland. There may however be ways in which the impact of this customs duty on business operations can be minimised. More information can be found in GOV.UK guidance about Trading and moving goods in and out of Northern Ireland.
Businesses could consider:
- Customs Duty Waiver
Businesses in Northern Ireland can claim a waiver for any customs duty on goods imported into Northern Ireland. This means that as opposed to using their own funds, they can offset from their De Minimis Aid allowance up to a maximum value of €300,000 over three tax years.
More information into how to claim a waiver and all reporting requirements can be found in our article about customs duty waiver.
- Duty Reimbursement Scheme
If you have declared goods as being "At Risk" and paid customs duty only for the goods in question to stay in Northern Ireland, you may be able to reclaim the duty payments via the Duty Reimbursement Scheme. This is a new scheme that was launched in June 2023. More information about this scheme including how to apply and what evidence is required can be found in our Duty Reimbursement Scheme article.
- Customs special procedures e.g. Inward Processing
In addition to the customs duty waiver or Duty Reimbursement Scheme some businesses may be eligible to avail of customs special procedures. Customs special procedures are mechanisms which allow businesses to avail of relief from/suspension of customs duty and VAT when imported.
One of the most common customs special procedures is known as Inward Processing Relief. This allows businesses who import goods which are subject to commercial processing before being exported outside of the EU to suspend the requirement to pay customs duty upon entry into either Northern Ireland/Ireland. Should these goods then be sold outside of Northern Ireland or the EU, there will be no subsequent requirement to pay the duty.
It is important to note that businesses seeking to use Inward Processing Relief will be required to obtain authorisation from HMRC prior to being able to use this procedure when importing.
We have more information about Inward Processing Relief including how to obtain authorisation.
Summary
Understanding when to pay customs duty/tariffs can be extremely complicated. By following the steps outlined above businesses can ensure that they correctly determine the appropriate rate of duty, and can ensure that steps are in place to manage the impact of customs duty on business operations.
Prepared by the InterTradeIreland Trade Hub Team
Article Published: August 2025