GB – Northern Ireland
For the EU, GB is simply a third country, which means NI has become a high-risk channel for illicit or sub-standard imports. Border management systems are essential at the GB-NI border and inevitably disrupt trade.
Under the WA, goods moving from GB to NI must comply with EU law on customs and regulation. The Protocol keeps NI in the EU’s single market for goods and the EU Customs Union. As a result, NI continues to apply EU rules as they relate to customs, trade, production and the regulation of goods.
From 1 January 2021, NI trade across the Irish border and with other EU countries continue on the same terms as before. This means no customs procedures, infrastructure or regulatory checks on goods exported to the EU, including across the Irish border.
At the GB-NI border, new UK-EU trade frictions occur. With the TCA, goods entering NI from GB, require:
- Import declarations and safety and security certificates;
- Export Health Certificates and SPS (sanitary and phytosanitary) checks – for animal and plant products.
Windsor Framework
The Windsor Framework covers a range of refinements to the operation of the Northern Ireland Protocol. These help reduce the level of checks on goods trade and will be phased in by 2025. The Withdrawal Agreement Joint Committee adopted the Framework on 24 March 2023. The key features are as follows.
- Goods going from GB to NI divide into those for NI (green lane) and those going to Ireland and the EU single market (red lane).
- Companies that use the green lane and register for a trusted trader scheme have greatly reduced customs paperwork (September 2023).
- Goods in the red lane go through full customs, food and animal health checks.
- For agri-food the EU accepts UK public health standards, which allows fresh meat and other goods to enter NI:
- these goods must carry “not for EU” labels, when only 5% of shipments will be subject to identity checks;
- seed potatoes and plants can be shipped to NI with a special plant health label (since September 2023).
- UK has agreed to share customs data with the EU (close to real time) in order to spot evidence of fraud and take remedial action if necessary (September 2024).
- Parcels to friends or family and online deliveries from GB will not require customs paperwork (2024).
- Businesses using approved parcel carriers will have simplified customs procedures (2024).
Other refinements include:
- Medicines approved for use in the UK can be sold in NI even if not yet approved in EU (2025).
- Pets travelling from GB to NI only need a simple travel document and owner’s declaration, and no longer need a micro-chip.
- Allowing NI to adopt domestic VAT rate changes (May 2023)
- Subsidies (state aid)
- Stormont Brake to allow NI possibility of objecting to EU rule changes requiring the UK and EU to discuss them before applying them.
- If NI still decides not to apply the rules, the Commission could apply remedial measures.
For further information on the Windsor Framework, see the House of Commons Library briefing on ‘The Northern Ireland Protocol and Windsor Framework’ (1 February 2024).
Independent review – 2025
The government had to commission an independent review into the functioning of the Windsor Framework. This followed on from the first democratic consent vote took place in the Northern Ireland Assembly in December 2024 because the vote did not achieve “cross-community support”. Although, a majority of Assembly members voted to support the continued application of certain goods-related EU laws in NI, all Unionist-designated members voted against.
Lord Murphy led the review, publishing its report on 4 September 2025. The UK government published its response on 16 December 2025. The Northern Ireland Secretary, Hilary Benn MP, said the government had accepted Lord Murphy’s 16 recommendations.
- Seven concern the perceived “democratic deficit”. They focus on improving:
- improving the operation of the Assembly’s Windsor Framework Democratic Scrutiny Committee;
- improving the transparency of the democratic scrutiny mechanisms;
- building capacity within the Northern Ireland Civil Service;
- strengthening the Northern Ireland Executive Office in Brussels.
- Eight address the impact of the Windsor Framework on business and trade. They focus on simplified administrative processes for businesses and improved guidance to provide more regulatory clarity:
- streamlining access to information and guidance on EU laws applicable in NI through an “all-in-one service” tailored to the needs of small and medium sized businesses;
- promoting the commercial benefits of dual market access (to Great Britain and the EU);
- supporting efforts to strengthen trade within the UK’s internal market;
- a “one stop shop” advice service which will be operational in financial year 2026-27;
- establish a Northern Ireland Trade Resolution Centre to deal with more complex issues.
- One relates to Article 2 of the Windsor Framework which provides a framework for safeguarding human rights and equality in Northern Ireland in areas previously underpinned by EU law.