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Blogs | 16 March 2023

The Windsor Framework Explained: what traders need to know

The EU and the UK have finally agreed on a deal to resolve the trade row over Northern Ireland. Following Brexit, the NI Protocol was put in place to avoid a hard border for Ireland, keeping NI in the EU’s single market for trade. This meant that businesses moving goods between GB and NI were required to comply with the new customs requirements. Multiple delays or grace periods were agreed upon to postpone the introduction of certain rules and checks at the time, but these were not sustainable for long-term trade. The good news? Under the new Windsor Framework, the current requirements for customs declarations for goods moving from GB to NI will no longer be required. The Windsor Framework aims to cut customs paperwork and checks on goods moving from GB but destined to stay in NI, ensuring the smooth flow of internal UK trade and safeguarding Northern Ireland's place in the European Union.


How will the Windsor Framework Agreement work?

Checks and controls on agricultural and food products have been simplified. The UK’s public health standards will be applied to agri-food goods being transported to Northern Ireland. Previously restricted products such as sausages can now be moved to Northern Ireland under the Protocol. Instead of requiring several certificates for each product, a single certificate along with a description of the goods will be enough for lorries carrying agri-food products.

Individuals sending parcels to NI will not need to provide customs paperwork. Similarly, if online businesses send parcels to individuals in Northern Ireland, they will only need to complete minimal customs processes. The Medicines and Healthcare products Regulatory Agency (MHRA), the UK regulator, will now regulate all medicines that are made available for sale in Northern Ireland, instead of the EU’s regulator. As a result, all medicines approved by the UK will be available for sale in Northern Ireland.

The ‘Green Lane’

While a date for new requirements hasn’t been announced, a new internal market system will be established in the UK for GB goods bound for sale in NI. These goods will travel along the ‘green lane’ whereby businesses can submit a reduced amount of data for their goods. As part of the Trusted Trader Scheme (TTS), businesses can submit standard commercial information for goods destined for the UK/NI. Only Trusted Traders can use the green lane.

The ‘Red Lane’

Goods deemed ‘at risk’ of entering the EU (including the Republic of Ireland) will travel along ‘red lanes’ and will continue to be subject to the same EU customs controls that apply for GB trade into the EU. This is also the case for traders not in the new TTS; they will be subject to full checks and controls to protect the EU Single Market.

VAT and Duty Implications

In Northern Ireland, a limit imposed by the EU on the number of reduced and zero rates of Value Added Tax (VAT) that can be applied to certain goods is no longer applicable. Additionally, an exemption has been agreed upon, which enables the zero rates of VAT on energy-saving materials' installation in immovable property, such as heat pumps and solar panels, as implemented in Great Britain, to also be applied in Northern Ireland.

Furthermore, it will also ensure that the planned reforms to alcohol duty can apply UK-wide. These measures will offer a pragmatic solution, preventing products from being pulled from the shelves and avoiding unnecessary price rises for consumers.


Goods destined for EU – Trader submits full EU customs and regulatory paperwork – HMG verifies customs documentation – HMRC shares data with EU – HMG regulatory, fiscal and anti-smuggling checks (1)


The Trusted Trader Scheme

The current trusted trader scheme known as the ‘UK Trader Scheme’ (UKTS) will be rolled over into the new Trusted Trader Scheme. The EU has toughened its criteria to become a trusted trader, with a new database tracking shipments of goods between GB and NI in rea;-time. A system will be introduced by the EU to track shipments in real-time.

While there are still some unknowns, businesses already registered for the TTS should be able to roll over their registration in September without having to apply again.

Businesses wishing to apply will need to demonstrate financial solvency and a clean bill of customs health – showing compliance in the last three years.


When will the new framework be put in place?

There is no definitive timeline, as there are still ongoing negotiations between the UK and the EU, but it is expected to come into force in the autumn. While some elements of the Windsor Framework have been agreed upon, traders should continue to complete declarations for GB-NI goods as they have been doing.

'We welcome the proposed changes simplifying the movement of goods between GB and NI. We look forward to the release of further details of the new scheme and the reduced administrative burden for traders.'

Zeeshan Ashraf, Principal Product Manager, C4T


Additional Documents

You can find the full UK Gov Windsor Framework document here.





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