Customs implications of trade with Northern Ireland

  1. Overview
  2. The Windsor Framework
  3. Protocol on Ireland and Northern Ireland

Protocol on Ireland and Northern Ireland

The United Kingdom (UK), including Northern Ireland (NI), is formally no longer a Member State of the European Union (EU).

The formalities for trade with Northern Ireland are set out in the Revised Protocol on Ireland and Northern Ireland (the Protocol) which entered into effect from 1 January 2021. The Protocol acknowledges the unique situation of Ireland and Northern Ireland through:

  • avoiding a hard border, including any physical infrastructure or related checks and controls, between Ireland and Northern Ireland
  • and
  • safeguarding the all-island economy and the Good Friday (Belfast) Agreement.

The Windsor Framework, which came into effect from 25 March 2023, provides joint EU and UK solutions to elements of the Protocol that were causing unforeseen difficulties in Northern Ireland.

References to the Protocol should be read as including the changes introduced by the Windsor Framework.

Implementation of the Protocol

Under the Protocol, Northern Ireland:

  • legally remains part of the customs territory of the UK
  • and
  • effectively remains within the EU Single Market for the movement of goods only.

This has the following practical implications for rules for trade in goods between Ireland, Northern Ireland and the EU:

  • No customs declarations, tariffs or quantitative restrictions.
  • No customs checks or controls on the island of Ireland.
  • No safety and security requirements.
  • Continuing access to the VAT Information System (VIES) for Northern Ireland traders to account for Value-Added Tax (VAT) on intra-Community acquisitions and supplies.
  • The movements of excisable products continue to be completed through the Excise Movement Control System (EMCS) by Northern Ireland traders. 

To safeguard the EU Single Market, the Protocol provides that Northern Ireland remains aligned to a limited set of EU rules related to goods. The Union Customs Code continues to apply to all goods entering Northern Ireland from Great Britain or other third countries (non-EU and EFTA countries).

Northern Ireland traders

In relation to the requirements for trade between Northern Ireland the EU, Great Britain and third countries, should consult HMRC for further guidance. 

Great Britain EORI numbers are no longer accepted on the EU customs systems. Northern Ireland EORI numbers have been updated with country code 'XI'. XI EORI numbers are accepted on the Irish customs clearance systems.