Windsor Framework

Summary

The Windsor Framework is the UK-EU agreement reached in February 2023 to revise the operation of the Protocol on Ireland/Northern Ireland. It is designed to protect Northern Ireland’s place in the UK internal market while preserving the absence of a hard border on the island of Ireland and safeguarding the EU Single Market. It does this through new arrangements for goods moving from Great Britain to Northern Ireland, including simplified processes for goods staying in Northern Ireland and full controls for goods moving onward into Ireland or the wider EU.

Details

Jurisdictions

Northern Ireland

Mandatory for

The Windsor Framework is mandatory where it applies through UK law, EU law, Withdrawal Agreement obligations and Northern Ireland implementation measures.

Businesses may face mandatory requirements where they:

Move goods from Great Britain to Northern Ireland.

Move goods from Northern Ireland to Ireland or the EU.

Use the UK Internal Market Scheme.

Supply retail agri-food goods to Northern Ireland.

Place medicines on the UK market.

Ship parcels or freight across GB-NI routes.

Handle SPS-controlled goods.

Move regulated goods that may enter the EU Single Market.

Use simplified customs routes.

Rely on “not at risk” treatment.

Exemptions

The Framework does not apply to all UK trade. It is specifically focused on Northern Ireland’s post-Brexit trading position and the operation of the amended Protocol.

Important limitations include:

Pure Great Britain domestic trade is generally outside the Framework.

Goods moving directly between Great Britain and non-EU countries are generally outside the Framework.

Goods staying wholly within Northern Ireland may still be subject to applicable local rules but not necessarily GB-NI movement requirements.

Simplified arrangements depend on eligibility and destination evidence.

Some retail goods are exempt from individual “Not for EU” labelling requirements, particularly where not subject to EU official controls.

Medicines have specific transitional and stock rules under MHRA guidance.

The key point for companies is that simplified treatment is conditional, not automatic.

Deep dive

8 min read

Updated Aug 17, 2026

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What’s Required

1. Distinction between goods staying in Northern Ireland and goods moving to the EU

The Windsor Framework introduced a clearer distinction between goods that are intended to remain in Northern Ireland and goods that may move onward into Ireland or the EU Single Market. Goods staying in Northern Ireland can use simplified UK internal market arrangements, while goods moving into the EU must follow fuller EU-facing controls.

In practice, businesses need to determine:

Where the goods are ultimately intended to be sold or used.
Whether the goods are “not at risk” of moving into the EU.
Whether customs duties may apply.
Whether the goods qualify for simplified movement arrangements.
Whether full EU controls apply.
Whether additional labelling, certification or documentation is required.

This destination-based logic is the core compliance feature of the Windsor Framework.

2. UK Internal Market Scheme and simplified movement routes

The Windsor Framework expanded the system for goods moving from Great Britain to Northern Ireland that are intended to stay in Northern Ireland. The Northern Ireland Assembly explains that the Framework established an expanded Internal Market Scheme, previously known as the “green lane”, for goods staying in Northern Ireland with simplified procedures.

For businesses, this can reduce paperwork and checks, but only where the conditions are met. Companies should maintain evidence on:

Customer location.
Final destination.
Product type.
Trader authorization.
Commercial records.
Transport route.
Whether goods could enter the EU market.
Whether the product falls into a category with special controls.

3. Red lane controls for goods moving to the EU

Goods moving onward to Ireland or the EU must use the full-control route, often described as the “red lane”. This means customs, SPS, product compliance and regulatory checks may apply depending on the product.

This is especially relevant for:

Agri-food.
Live animals.
Plants.
Seeds.
Chemicals.
Product-regulated goods.
Waste and recyclable materials.
Medicines and medical products.
Consumer goods.
Retail products.
Industrial components.

4. “Not for EU” labelling for certain retail goods

The Windsor Framework introduced “Not for EU” labelling requirements for certain retail goods moving from Great Britain to Northern Ireland under the simplified arrangements. Northern Ireland Assembly timeline material notes that from 1 July 2025, all retail goods other than goods sold loose should be individually labelled, with some exceptions for goods not subject to EU official controls, such as confectionery, chocolate, pasta, biscuits and coffee.

For suppliers, this affects:

Packaging design.
SKU management.
Labelling systems.
Stock segregation.
Distribution planning.
Retail compliance.
Traceability.
Product recall systems.

Incorrect labelling can create both market access and reputational risk.

5. Agri-food and SPS controls

The Windsor Framework changes the operation of sanitary and phytosanitary controls for goods moving from Great Britain to Northern Ireland. Retail goods intended to stay in Northern Ireland can benefit from simplified arrangements, while goods moving onward to the EU remain subject to full controls.

Companies handling food, drink, plants or animal products should assess:

Certification requirements.
Official controls.
Labelling duties.
Retail movement scheme eligibility.
Veterinary or phytosanitary requirements.
Cold chain and logistics documentation.
Border control post requirements.
Final destination evidence.

6. Medicines and healthcare product arrangements

The Windsor Framework introduced important changes for medicines. UK Government guidance explains that from 1 January 2025, all UK medicinal products must carry a clearly legible “UK Only” label to be placed on the UK market, with certain specific exceptions and transitional provisions.

For pharmaceutical and healthcare companies, this affects:

UK-wide product authorizations.
Packaging artwork.
Labelling.
Batch release.
Distribution.
Stock management.
Regulatory submissions.
Northern Ireland supply continuity.
EU market separation.

7. Parcels, freight and customs data

The Windsor Framework also affects parcels and freight moving between Great Britain and Northern Ireland. The implementation timeline notes that new arrangements for goods moving by parcels or freight under the Framework take effect as part of the staged implementation process.

Businesses should prepare for:

Data requirements.
Carrier declarations.
B2B and B2C distinctions.
Consumer parcels.
Commercial freight.
Customs simplifications where eligible.
Full declarations where required.
Evidence of goods staying in Northern Ireland.

8. Democratic oversight and the Stormont Brake

The Windsor Framework introduced the Stormont Brake, a mechanism intended to give Northern Ireland institutions a role in relation to certain new EU goods rules that would otherwise apply under the Framework. UK Government materials described this as a way to address democratic deficit concerns.

For companies, the practical relevance is that certain regulatory changes may be politically contested or delayed. Compliance teams should monitor updates rather than assume the regulatory position is static.

Important Deadlines

27 February 2023: agreement announced

The UK Government and European Commission announced agreement in principle on the Windsor Framework on 27 February 2023.

24 March 2023: formal adoption through the Joint Committee

The UK and EU formally adopted key elements of the Windsor Framework through the Withdrawal Agreement Joint Committee on 24 March 2023.

30 September 2023: UK Internal Market Scheme replaced UK Trader Scheme

UK Government implementation material notes that the existing UK Trader Scheme was replaced by the UK Internal Market Scheme from 30 September 2023.

1 January 2025: UK-only medicines labelling

From 1 January 2025, UK medicinal products placed on the UK market must carry “UK Only” labelling under Windsor Framework medicines arrangements.

1 July 2025: final phase of “Not for EU” retail food labelling

From 1 July 2025, the final phase of retail goods labelling requirements came into force, with individual “Not for EU” labelling applying to most retail goods, subject to exceptions.

28 July 2025: final SPS inspection facilities deadline

Northern Ireland Assembly timeline material notes that final SPS inspection facilities should be operational at Belfast, Larne, Foyle and Warrenpoint by 28 July 2025.

Current Status

The Windsor Framework is active and legally operational. It is the current UK-EU framework governing the amended Protocol on Ireland/Northern Ireland. EUR-Lex states that, reflecting Joint Committee Decision No 1/2023, the Protocol as amended should now be known as the Windsor Framework.

Current status:

Agreed in February 2023.
Formally adopted in March 2023.
In implementation through UK and EU legal measures.
Applies to trade and regulatory arrangements involving Northern Ireland.
Includes simplified arrangements for goods staying in Northern Ireland.
Preserves EU-facing controls for goods entering Ireland or the EU.
Includes staged labelling, medicines, customs, parcels and SPS implementation.
Continues to be managed through UK-EU Withdrawal Agreement structures.
Legally connected to the Withdrawal Agreement, which the European Commission describes as a legal obligation under international law.

The Framework should be treated as a trade and regulatory framework, not a sustainability law. Its sustainability relevance comes through product compliance, supply-chain traceability, food systems, waste, packaging, logistics and regulatory alignment.

Penalties for Non-Compliance

Penalties arise through UK, EU and domestic enforcement systems rather than through the Windsor Framework as a standalone regulator.

Possible consequences include:

1. Customs delays or refusal

Goods may be delayed, stopped or redirected if documentation, scheme eligibility or destination evidence is incomplete.

2. Loss of simplified movement access

Traders that fail to meet UK Internal Market Scheme conditions may lose access to simplified procedures.

3. Duties and financial liabilities

Goods treated as “at risk” of entering the EU may face EU customs duties, with possible repayment or reimbursement mechanisms where applicable.

4. Product seizure or withdrawal

Incorrectly labelled, misdeclared or non-compliant goods may be seized, withdrawn or prevented from being placed on the market.

5. Administrative penalties

Customs, trading standards, food safety, medicines, SPS or product regulators may impose penalties under relevant domestic law.

6. Criminal enforcement

Deliberate fraud, false declarations, smuggling, counterfeit medicines, illegal food movements or customs evasion may trigger criminal enforcement.

7. Contractual liability

Retailers, logistics providers, manufacturers and distributors may face contract breaches if goods cannot be supplied, labelled or cleared as promised.

8. Reputational risk

Non-compliance can affect consumer trust, especially for food, medicines, healthcare products and goods labelled “Not for EU” or “UK Only”.

Examples of Known Violations / Failure Modes

Typical violations and failure modes include:

Moving goods through the simplified route when they are actually intended for Ireland or the EU.
Failing to maintain evidence that goods are staying in Northern Ireland.
Misusing the UK Internal Market Scheme.
Incorrectly applying “Not for EU” labels.
Selling “Not for EU” goods into Ireland or the wider EU.
Failing to update packaging by required deadlines.
Using obsolete stock without checking transitional rules.
Misclassifying goods as not at risk of entering the EU.
Omitting SPS certification where full controls apply.
Moving retail food products without required labelling or documentation.
Failing to separate Northern Ireland, Great Britain and EU SKUs.
Supplying medicines without required “UK Only” packaging rules.
Treating Northern Ireland as identical to Great Britain for product compliance.
Treating Northern Ireland as identical to the EU for all product compliance.
Failing to update customs processes after staged implementation dates.

Resources

Added by:

Maílis Carrilho

Sustainability Research Analyst

Maílis Carrilho is a Sustainability Research Analyst (Intern) at Net Zero Compare, contributing research and analysis on climate tech, carbon policies, and sustainable solutions. She supports the team in developing fact-based content and insights to help companies and readers navigate the evolving sustainability landscape.

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Added on Aug 20, 2026 by Maílis Carrilho · Updated on Aug 17, 2026

Suggest an edit

Windsor Framework: Establishes Northern Ireland Trade, Product and Regulatory Controls Across UK-EU Supply Chains