Dual Market Access explained

Dual Market Access grants Northern Ireland goods the unique ability for goods to move without restrictions into two major economic spaces:  

  • The United Kingdom's internal market: This includes Great Britain (England, Scotland, and Wales) and Northern Ireland itself.
  • The European Union's single market: This encompasses the 27 EU member states.  

This access extends to the European Economic Area (EEA) countries: Norway, Liechtenstein, and Iceland, which are part of the EU's Single Market arrangements.

Why Northern Ireland Has Dual Market Access

Following the 2016 UK referendum on EU membership, concerns arose about the potential for a physical customs border on the island of Ireland. Many viewed such a border as a threat to both the peace process and economic stability.

The Withdrawal Agreement between the UK and the EU sought to avoid this. It included the Ireland/Northern Ireland Protocol. This protocol, now adapted through the Windsor Framework, enables Northern Ireland to retain access to the EU Single Market for goods. This ensures largely frictionless trade, with no customs declarations or tariffs on goods moving directly between Northern Ireland and the EU.

How Dual Market Access works in practice

Several key processes govern how Dual Market Access functions for the movement of goods:

  • Goods Moving from Great Britain to Northern Ireland: These movements require new administrative procedures, including declarations. EU 'Third Country' Tariffs may apply to goods deemed 'At Risk' of entering the EU or those not meeting UK-EU Trade & Cooperation Agreement preferential origin rules. However, once customs clear these goods, they are in 'Free Circulation' within both the UK and EU markets.
  • Qualifying Northern Ireland Goods (QNIG): Goods originating in or in free circulation within Northern Ireland can move freely within both the UK internal market and the EU Single Market. A QNIG is a good physically located in Northern Ireland, not under a special customs procedure at the point of sale.
  • Important considerations for goods entering Northern Ireland from Great Britain (and other non-EU countries): Only goods classified as 'at risk' upon entry can circulate freely in both the UK and EU markets. The UK Internal Market Scheme (previously the UK Trader Scheme) dictates that goods declared as 'not at risk' must remain within the UK internal market. Businesses must retain evidence of this for five years.
  • Requirements for Northern Ireland goods moving to Great Britain: Only Qualifying Northern Ireland Goods (QNIG) have unfettered access to the GB market. For goods originating outside Northern Ireland, Northern Ireland businesses must also demonstrate a legitimate business or logistical reason for routing goods through Northern Ireland to Great Britain; this reason must not primarily aim to avoid customs duties or obligations connected with such duties that would be chargeable as a result of the Taxation (Cross-border Trade) Act (TCTA). See Notices made under the Customs (Northern Ireland) (EU Exit) Regulations 2020 which have force of law.

Dual Market Access uniquely positions Northern Ireland, allowing certain goods to benefit from regulatory alignment with the EU while also enjoying full access to the UK's internal market, albeit with specific rules and conditions governing the movement of goods in both directions.

Find out more about how these process apply to your business, see key considerations and moving goods. 

The Windsor Framework

The Windsor Framework is an agreement that establishes arrangements for the movement of goods between Great Britain and Northern Ireland.

While many of the Windsor Framework's arrangements are already in place, some are yet to be implemented. View a timeline of important dates. 

It includes several key provisions: 

UK Internal Market Scheme

UK Internal Market Scheme

The UK Internal Market Scheme (UKIMS) makes it easier to sell goods in Northern Ireland and across the UK by reducing paperwork, checks, and duties.

Here are the key aspects of the UK Internal Market Scheme:

  • Once fully implemented, authorised Trusted Traders will benefit from significantly reduced data requirements when transporting goods from Great Britain to Northern Ireland. Instead of providing over 80 data points, they will only need to provide 21
  • The scheme will also remove the need for Supplementary Declarations for consignments moving from Great Britain to Northern Ireland that are classified as 'not at risk'
  • UKIMS offers benefits to a broader range of businesses compared to the previous UK Trader Scheme (UKTS). This includes businesses based in Great Britain and Commercial Processors with a turnover of up to £2 million (an increase from the previous £500,000 threshold). It also covers businesses involved in specific exempted end-uses such as Construction, Animal-Feed, Healthcare, Consumer Food-Production, and Not-For-Profit organisations

It is important to note the following limitation:

The simplifications offered by UKIMS only apply to 'not at risk' consignments that are moved by traders authorised under the scheme. Goods moving from Great Britain to Northern Ireland that are intended for the EU or are considered 'at risk' of entering the EU at the point they enter Northern Ireland will still be subject to full EU Customs Checks and Controls, including Sanitary and Phytosanitary (SPS) Controls

Further guidance on UKIMS

Find clear guidance on the rules for moving goods between Great Britain and Northern Ireland to ensure compliance with post EU exit trade requirements. See Internal Market Movements from Great Britain to Northern Ireland.

Find guidance on eligibility criteria and procedures to classify goods as 'Not At Risk' of moving to the EU to avoid unnecessary tariffs for Northern Ireland manufacturers sourcing from Great Britain. See moving goods you bring into Northern Ireland as 'not at risk’ of moving to the EU.

Find clear guidance on declaring goods as ‘Not At Risk’ of entering the EU to help businesses reduce tariffs and simplify trade - see apply for authorisation for the UK Internal Market Scheme if you bring goods into Northern Ireland.

Duty Reimbursement Scheme

The Duty Reimbursement Scheme lets businesses claim back EU customs duties paid on 'at risk' goods imported into Northern Ireland, as long as the goods were sold or used outside the EU.

Apply to claim a repayment or remission of import duty on ‘at risk’ goods brought into Northern Ireland.

Northern Ireland Retail Movement Scheme

Under the Windsor Framework, Trusted Traders in the Northern Ireland Retail Movements Scheme (NIRMS) can move retail goods from Great Britain to Northern Ireland for local consumption without facing strict regulatory barriers.

Find out more about NIRMS.

GB-NI parcel movements

The Windsor Framework introduces new rules for moving goods between Great Britain and Northern Ireland, covering parcels and freight. The new rules came into effect on 1 May 2025.

Find out more about sending parcels between Great Britain and Northern Ireland under the Windsor Framework.

Watch the tutorial

Watch the video to learn more about how Dual Market Access works. 

View the presentation

Download the Dual Market Access presentation (PDF).