Guides / Northern Ireland and the Windsor Framework · Updated 30 September 2026

Northern Ireland and the Windsor Framework: a guide for traders

Moving goods from Great Britain into Northern Ireland, or from Northern Ireland on to Poland, follows different rules in each direction. Here is what HMRC guidance says about UKIMS, goods not at risk, XI EORI numbers and VAT.

Northern Ireland sits in an unusual position for traders. It is part of the UK customs territory, yet under the Windsor Framework EU rules continue to apply there to goods in several important respects, including VAT. That means the paperwork you need depends on which direction your goods travel: from Great Britain into Northern Ireland, or from Northern Ireland onwards into the EU, for example to Poland. This guide walks through both, using only what HMRC and GOV.UK guidance states.

Why direction of travel matters

Most traders meet the Windsor Framework in one of two situations. A business in England, Scotland or Wales sends stock to a shop, warehouse or customer in Northern Ireland. Or a business in Northern Ireland sells goods to a customer in the EU. The first movement is where the UK Internal Market Scheme and the idea of goods "not at risk" come in. The second movement is governed mainly by the fact that Northern Ireland stays aligned with the EU single market for goods and EU VAT rules for goods.

Great Britain to Northern Ireland: "at risk" and "not at risk"

When goods are brought into Northern Ireland from Great Britain, the key question is whether they are at risk of moving on into the EU. GOV.UK explains the consequence in simple terms: goods treated as "at risk" are charged the applicable EU rate of duty, while goods correctly declared "not at risk" can move with reduced or no duty.

According to HMRC guidance, you can declare goods "not at risk" under the UK Internal Market Scheme (UKIMS) when all of these apply:

• the goods are for sale to, or final use by, end consumers located in the UK;
• the person bringing them in is authorised under the UK Internal Market Scheme;
• the goods are not subject to an EU trade remedy.

GOV.UK also notes that goods in free circulation in Great Britain can be moved as "not at risk" where the applicable EU rate of duty is zero. Goods that go on to be processed in Northern Ireland face extra conditions: businesses above a stated turnover level must show that the processed goods serve approved purposes, such as food sold to UK consumers or construction installed in Northern Ireland. Check the current guidance before relying on the processing rules, as they are detailed.

Where the "green lane" fits

Industry commentary often talks about a "green lane" and a "red lane". The GOV.UK pages we checked are more cautious in their wording: they describe the customs side mainly through the "not at risk" and "at risk" categories, and one retail movement page refers to goods that "benefit from the customs elements of the Green Lane" by being declared "not at risk" for tariff purposes. In practice, the safest approach is to think in HMRC's terms: either your goods meet the "not at risk" criteria under UKIMS, or they are treated as "at risk" and the applicable EU duty is charged. If duty is paid on goods that later prove eligible, HMRC guidance refers to claiming a repayment or remission of the import duty.

Applying for the UK Internal Market Scheme

UKIMS gives authorised traders simplified customs procedures for moving goods from Great Britain into Northern Ireland. HMRC's eligibility requirements include:

• being established in the UK;
• a good customs and tax compliance record, assessed over the preceding three years;
• no serious criminal offences relating to economic activity;
• good financial standing;
• an understanding of the scheme's obligations and procedures.

If your business has an office in Northern Ireland, HMRC expects permanent human and technical resources there. If you are based elsewhere in the UK, you need an indirect customs representative in Northern Ireland. Remember what indirect representation means: the agent is jointly liable with you for the declaration, which is why representatives check your records carefully. Our guide on whether you need a broker covers the difference between direct and indirect representation.

EORI numbers: GB, XI or EU

Northern Ireland movements often need an EORI number starting with XI rather than GB. The UKIMS guidance says businesses registered in Northern Ireland must apply using an XI EORI, while businesses elsewhere in the UK may use a GB or XI number, preferably XI where they have one. GOV.UK's general Northern Ireland trading guidance adds that you may need an XI EORI when moving goods between Northern Ireland and non-EU countries, which for these purposes includes Great Britain.

EU businesses are treated differently. If your business is established in an EU country, HMRC says you must use an EORI number from an EU country to move goods in and out of Northern Ireland, including for full import and export declarations in the Customs Declaration Service and movements through the Goods Vehicle Movement Service. You must first subscribe to CDS with that EU EORI. HMRC lists exceptions where a GB number should still be used, for example when operating under UKIMS or using postponed VAT accounting.

Northern Ireland to Poland and the rest of the EU

The other direction is simpler on the customs side. GOV.UK states that declarations are not needed for goods moving directly from Northern Ireland to the EU. These are treated as movements within the EU single market for goods, so a Northern Ireland business selling to a customer in Poland does not file an export declaration in the UK or an import declaration in Poland for a direct movement.

VAT is where the work lies. Under the Windsor Framework, EU VAT rules continue to apply in Northern Ireland in respect of goods. GOV.UK tells businesses to register as operating under the Windsor Framework and to put an "XI" prefix before their UK VAT number on all documentation when dealing with EU customers or suppliers. For a Polish buyer, that XI number is what identifies your business for intra-EU VAT purposes.

The word "directly" matters. Goods routed from Northern Ireland through Great Britain before reaching the EU are no longer a simple single-market movement. If you use a route that leaves Northern Ireland via a GB port, for example a ferry to Scotland and then a crossing from the south coast, the goods leave the UK from Great Britain to the EU, and normal export and import formalities, and potentially T1 transit, come back into play. Plan the route before you quote delivery terms.

A practical checklist

If you are sending goods from Poland into Northern Ireland instead, the picture is different again, and the Windsor Framework guide for Polish exporters sets out that route from the EU side. Whichever direction you trade in, the right EORI and a clear view of where the goods will finally be used decide most of the paperwork.

Related guides

• Tracking a customs clearance in Poland for goods from the UK

• Selling EU cosmetics into Great Britain: a seller's checklist

• Customs procedure 42: VAT-exempt import and onward EU supply

Sources

• Moving goods you bring into Northern Ireland as 'not at risk' of moving to the EU (GOV.UK)
• Apply for authorisation for the UK Internal Market Scheme (GOV.UK)
• Trading and moving goods in and out of Northern Ireland (GOV.UK)
• Using an EORI number from an EU country for goods moving in and out of Northern Ireland (GOV.UK)
• Northern Ireland Retail Movement Scheme: groupage and mixed load consignments (GOV.UK)

General information, not legal, tax or customs advice. Rules change; confirm current requirements on gov.uk or with a registered agent before you ship.