The Windsor Framework is a game-changer for online retailers operating between Great Britain and Northern Ireland. It refines rules introduced by the Northern Ireland Protocol, aiming to reduce trade frictions and enhance market opportunities. For e-commerce businesses, staying compliant and leveraging these new paths for growth is critical.
Brenda Varela
Last Updated on 28 March 2025
In this article, we’ll break down the key elements of the Windsor Framework, its potential impact on VAT and customs, and practical steps to adapt. Whether you’re a seasoned seller or exploring the Northern Irish market for the first time, you’ll find the insights you need to keep shipments smooth and compliant.
How the Windsor Framework Impacts Online Sellers?
TThe Windsor Framework modifies existing regulations under the Northern Ireland Protocol. It introduces:
- Green Lanes for goods staying in Northern Ireland, reducing customs checks.
- Red Lanes for goods potentially bound for the EU, requiring full customs procedures.
For online sellers, these lanes simplify VAT and customs obligations, making it easier and faster to ship products to Northern Ireland. The framework aims to maintain a smooth flow of goods within the UK while respecting EU market rules where necessary.
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Key Components: Green Lanes, Red Lanes, and Customs Simplification
Green Lanes
- Fewer Checks: Goods identified as “not at risk” of entering the EU enjoy minimal customs formalities.
- Faster Deliveries: Reduced inspections translate into quicker shipping, improving customer satisfaction.
Red Lanes
- Full Checks: Goods at risk of moving into the EU follow regular customs procedures.
- Ongoing Compliance: Businesses must ensure products meet EU standards and complete necessary documentation.
Simplified Customs for B2B and B2C
- B2B: Companies sending goods from Great Britain to Northern Ireland can register with the UK Internal Market Scheme (UKIMS) for reduced customs data requirements if goods are “not at risk.”
- B2C: Retailers shipping directly to end-consumers in Northern Ireland can bypass extensive declarations if parcels remain solely within Northern Ireland.
Learn more about EU VAT compliance for online sellers on our blog.
Impact on Online Sellers: New VAT and Labeling Rules
Impact on Online Sellers: New VAT and Labeling Rules
The Windsor Framework impacts both pricing strategies and product labeling:
VAT Adjustments
- Goods shipped within Northern Ireland may require different VAT treatments depending on whether they stay there or move into the EU.
- Keeping accurate VAT records is crucial for reclaiming duties or complying with tax authorities.
Labeling Requirements
- Certain products, such as medicines, will need a “UK only” label from 1 January 2025.
- Responsible Person obligations: Non-food products may need local contact details and manufacturer info, aligning with both UK and EU rules.
Packaging Changes
- “Not for EU” labels may be necessary for goods only intended for Northern Ireland.
- Staggered deadlines and transitional periods help businesses adjust.
Product-Specific Changes: Medicines and Seed Potatoes
Medicines and Pharmaceuticals
- January 2025 Deadline: The UK’s Medicines and Healthcare products Regulatory Agency (MHRA) will handle approvals.
- Uniform Packaging: A single “UK only” label is required across Great Britain and Northern Ireland.
- Reduced Complexity: EU anti-counterfeit measures no longer apply for Northern Ireland medicines, helping prevent supply issues.
Seed Potatoes
- Trade Resumption: Previous bans on moving seed potatoes between Great Britain and Northern Ireland are lifted.
- Plant Passport Scheme: Ensures traceability and safety across the UK, easing prior regulations and delays.
Stormont Brake: Northern Ireland’s Role in EU Regulations
A key mechanism in the Windsor Framework is the Stormont Brake:
- How It Works: If 30 Northern Ireland Assembly members from two or more parties object to a new EU regulation, it can be temporarily halted.
- Local Impact: This system allows Northern Ireland to maintain a balance between market alignment with the EU and sovereignty within the UK.
Phased Implementation and Transition Timeline
- 1 October 2023: Introduction of the Northern Ireland Retail Movement Scheme (NIRMS) for prepacked retail goods.
- 30 September 2024: Customs Duty Scheme starts for goods in the Red Lane.
- Originally March 2025.
- Official Delay to 1 May 2025.
While these dates may shift, the objective is to give businesses time to update procedures, adjust labeling, and train staff. It is also important to note that the Windsor Framework amends the Northern Ireland Protocol rather than fully replacing it.
Benefits and Challenges for E-Commerce Businesses
Benefits
- Reduced Trade Friction: Green Lane simplifications minimize customs checks.
- Enhanced Market Access: Northern Ireland retains access to both the UK internal market and the EU single market.
- Cost Savings: Higher customs duty waiver limits and streamlined VAT rules can lower operational expenses.
Challenges
- Complex Compliance: Some goods still face detailed EU checks, especially if they might cross into the Republic of Ireland.
- Labeling Deadlines: The shift to “UK only” labels and new packaging rules requires planning and potential cost implications.
- Changing VAT Landscape: Sellers must stay updated on evolving tax regulations and ensure record-keeping is accurate.

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Staying Informed and Preparing for the Future
Online retailers should regularly monitor official updates and use available resources:
- UKIMS Registration: Ensure you’re enrolled to benefit from streamlined customs processes.
- Cost Tracking: Keep evidence of costs for potential retrospective payments related to new labeling.
- Invest NI & InterTradeIreland: Explore support programs, training, and grants to navigate regulatory shifts.
Pro Tip:
Reviewing your supply chain for potential EU “risk” points can help avoid unexpected duties or regulatory obstacles.
Conclusion & Next Steps
The Windsor Framework creates a more manageable, future-focused environment for online sellers dealing with Northern Ireland. Fewer customs checks, streamlined VAT obligations, and new labeling rules open opportunities—and challenges—for e-commerce businesses. By staying informed, adjusting compliance strategies, and leveraging available resources, you can position your business for continued growth and success in this dynamic cross-border market.
Looking for expert guidance on VAT compliance and cross-border logistics? Contact hellotax for a free consultation and let our specialists streamline your operations under the Windsor Framework.
Further Reading
Note: This article is for informational purposes and does not constitute legal advice. Always consult with a professional to address your specific business needs.