Moving goods: navigating Dual Market Access

When goods move from Northern Ireland to Great Britain, the primary principle is that Qualifying Northern Ireland Goods (QNIG) have unrestricted access to the UK's internal market. The UK Government has made a firm commitment to ensure that Northern Ireland businesses face no additional standards or regulations when trading these goods with Great Britain.

Here's a breakdown of the applicable regulations:

• Unfettered Access for QNIG: Goods that meet the criteria for Qualifying Northern Ireland Goods (QNIG) benefit from unrestricted access to the internal UK market. This means they do not need to meet any extra UK legal, licensing, certification, marking, labelling, or marketing standards beyond those already applicable in Northern Ireland. QNIG status is typically achieved if the goods are manufactured in Northern Ireland using components that were in free circulation in NI at the point of processing or for finished products, are in free circulation within Northern Ireland at the time of sale.

• Acceptance of Northern Ireland Markings: For example, because both the CE and UKNI markings are valid in Northern Ireland, products bearing these markings that qualify as Northern Ireland goods can be sold in Great Britain without the additional requirement for the UKCA marking.

• VAT Treatment: For Value Added Tax (VAT) purposes, sales between Northern Ireland and Great Britain are treated as domestic UK sales. Therefore, standard UK VAT rules apply. If the Northern Ireland business is VAT registered, they will charge UK VAT at the appropriate rate to their customers in Great Britain.

The context for these regulations is as follows:

• While the UK's departure from the EU allows it to diverge from EU goods regulations (which the UK had to follow as a member), the Windsor Framework and Northern Ireland Protocol mean Northern Ireland continues to align with certain EU rules on goods. This creates the potential for regulatory divergence between Northern Ireland and Great Britain.
• However, the UK Government's commitment to unfettered access for QNIG aims to prevent additional burdens on Northern Ireland businesses trading within the UK.

The border between Northern Ireland (part of the UK) and Ireland (an EU member state) is the only land border between the United Kingdom and the European Union.

The Windsor Framework and Northern Ireland Protocol, agreed between the UK and the EU, prevented the need for a hard border between the UK and the EU, thereby avoiding physical customs infrastructure between Northern Ireland and Ireland.

To manage the specific arrangements for Northern Ireland, commercial goods moving from Great Britain to Northern Ireland must follow new administrative procedures. These include completing declarations and potentially applying EU 'third country' tariffs to goods classified as at risk of entering the EU or those not meeting the UK-EU Trade & Cooperation Agreement UK Preferential Origin requirements. However, once these goods are cleared, they are considered to be in 'free circulation' within both the UK and EU markets. This system provides Dual Market Access for Northern Ireland, allowing Qualifying Northern Ireland Goods to move freely within the UK internal market and between Northern Ireland and the EU Single Market.

While commercial shipments entering Northern Ireland from Great Britain are subject to administrative requirements, no export declarations are needed in Great Britain.

To help businesses meet the requirements in Northern Ireland, the UK Government established the Trader Support Service (TSS). UK traders can choose to use this free service provided by the UK government to complete customs declarations themselves.

The TSS is a complimentary digital service that includes the Northern Ireland Customs & Trade Academy. It is designed to help UK businesses and traders of all sizes navigate the changes that have been in place since 1 January 2021. The Trader Support Service assists traders and their carriers by generating declarations for goods moving from Great Britain to Northern Ireland using the data they provide. It also offers education and advice on the changes introduced by the Windsor Framework and the Northern Ireland Protocol, along with contact centre support for resolving issues.

Although tariffs may be applied to goods at risk of entering the EU when moving from Great Britain to Northern Ireland, these can be removed or waived under UK Preferential Origin rules or by using the trader's de minimis allowance of €300,000 (over a rolling 36 month period.)

Since 1 May 2025, the associated customs administrative requirements for moving commercial goods from Great Britain to Northern Ireland only apply to consignments either destined for or considered at risk of entering the EU Single Market. 'Trusted traders' authorised under the UK Internal Market Scheme (UKIMS) who can self-certify at the time of movement that the goods entering Northern Ireland are for sale to or end-use by consumers in Northern Ireland or the United Kingdom only (and are therefore not at risk of entering the EU), and who have evidence to support this, no longer need to complete import declarations, including supplementary declarations. EU 'third country' tariffs have also been removed on these internal UK deliveries. Instead, any movements declared as not at risk of entering the EU, can take place under the new Simplified Process for Internal Market Movements (SPIMM) with the UKIMS authorised party submitting Internal Market Movement Information (IMMI) either in advance of, or after the movement takes place. Traders in GB and NI can check eligibility and steps to take before moving goods. 

New rules for sending parcels between Great Britain and Northern Ireland under the Windsor Framework also came into effect from 1 May 2025 for both business to business and business to consumer parcels. 

When goods travel between Northern Ireland and the European Union using the Great Britain landbridge, or from Great Britain to Northern Ireland via Ireland, the Common Transit Convention (CTC) can be utilised. This transit procedure allows the movement of goods without the need to open and close import and export declarations as the cargo passes through the different territories.

Since leaving the European Union, the United Kingdom remains a signatory to the Common Transit Convention (CTC). To operate under this convention, the driver of the vehicle transporting the goods must carry a Transit Accompanying Document (TAD). This document contains a unique Movement Reference Number (MRN), which the consignor of the goods provides.

The United Kingdom has 40 free trade agreements with various nations and trade blocs, encompassing 102 countries and territories. These agreements include significant deals with:

• Australia
• New Zealand
• India
• The Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP), which the UK joined in December 2024 and includes twelve countries in the Asia-Pacific region

Therefore, businesses in Northern Ireland can leverage these UK Free Trade Agreements to facilitate trade with countries outside of the European Union, potentially benefiting from reduced tariffs and other preferential terms, provided their goods meet the specific rules of origin outlined in each agreement.

Goods entering Northern Ireland from countries outside the UK and the EU must comply with all UK import regulations relevant to the specific product and its country of origin and dispatch.

It's important to note the treatment of goods considered at risk of entering the European Union:

• If imported products are classified as at risk of entering the EU (this automatically applies to goods with safeguarding tariffs like Anti-Dumping Duty or Tariff Rate Quotas, or when the EU tariff is 3% or higher than the UK tariff), they will be subject to EU 'third country' tariffs upon import into Northern Ireland
• However, in many situations, importers can mitigate this cost. They may be able to waive or reclaim the difference between the UK and EU duty through their de minimis allowance or by using the Duty Reimbursement Scheme after the goods have cleared customs

When businesses in Northern Ireland sell goods to EU countries, they largely follow the same regulations that apply within Northern Ireland for placing goods on the market. This is a direct result of the Windsor Framework and the Northern Ireland Protocol, which keeps Northern Ireland aligned with EU rules on goods. Therefore, Northern Ireland businesses generally do not face extra requirements when selling into the EU compared to selling within Northern Ireland.

Here's a breakdown of the key regulations:

• EU Product Standards and Conformity Markings: Goods must meet EU standards, often demonstrated by EU conformity markings like the CE mark. These markings show that the product complies with the necessary EU technical requirements for various consumer and commercial goods.  

• General Product Safety Regulations (GPSR): As of 13th December 2024, the EU's General Product Safety Regulations (GPSR) replaced the 2005 version in Northern Ireland. This regulation aims to ensure consumer safety by placing responsibilities on all actors in the supply chain for safe and sustainable products. The GPSR covers most consumer goods not already subject to specific regulations with similar safety provisions (like those requiring the CE mark).  

• Authorised Representative (AR) for Non-EU Manufacturers: Typically, manufacturers based outside the EU need an Authorised Representative within the EU. However, due to the Windsor Framework, Northern Ireland manufacturers are considered to have met the EU's establishment criteria under GPSR. This means they do not need an AR to sell into the EU. Furthermore, they can act as an AR for non-EU manufacturers, including those in Great Britain without an EU, EEA, or Northern Ireland presence.  

• No Additional Requirements: Because Northern Ireland aligns with EU rules on goods, there are no additional requirements imposed on Northern Ireland businesses when selling into the EU. The rules for placing goods on the market are essentially the same in both Northern Ireland and the EU Single Market.  

• VAT Rules: Sales of goods from Northern Ireland businesses to businesses in the EU are treated as EU intracommunity supplies. This means the sale is zero-rated for VAT in Northern Ireland, and the EU customer accounts for the VAT as if they made the supply themselves. Northern Ireland businesses must use the prefix 'XI' before their UK VAT number on all documentation when dealing with EU customers or suppliers.  

• Distance Selling to EU Consumers (B2C): Northern Ireland businesses selling directly to consumers in the EU via phone, online, or other distance methods are subject to EU distance selling regulations, with Northern Ireland considered part of the EU for these purposes. They can utilise the One Stop Shop (OSS) Union scheme to manage the VAT on these sales across the EU in a simplified manner.  

The unique position of Northern Ireland under the Windsor Framework means that its businesses largely operate under the same goods regulations as the EU, simplifying trade between Northern Ireland and EU member states.