Windsor Framework for GB→NI parcels – what changes for B2B and B2C [2024–2026]

Trade between Great Britain (GB: England, Scotland, Wales) and Northern Ireland (NI) has been subject to complex customs negotiations between the UK and the EU since 2021. The Northern Ireland Protocol, which originally governed these arrangements, caused so many operational and political problems that it was replaced by the Windsor Framework in March 2023. This broad political and legal agreement is being implemented in stages and aims to separate the flow of goods destined for the UK market from goods at risk of entering the EU's single market. For businesses, freight forwarders, and consumers, the most significant changes concern parcels — in both B2B (business-to-business) and B2C (business-to-consumer) trade. The Windsor Framework introduces a "Green Lane" for qualifying goods (simplified formalities, no duty), a "Red Lane" for goods requiring full checks, a special Personal Package Limit for private parcels, and a range of provisions for different product categories. This article explains what the Windsor Framework has changed in practice for GB→NI shipments, and what is still due to change by 2026.

What the Windsor Framework changed compared to the Northern Ireland Protocol

The Northern Ireland Protocol (part of the UK Withdrawal Agreement, 2020) required NI to apply EU customs and sanitary rules to goods arriving from GB. In practice, this meant that every shipment from England to Belfast formally crossed a customs border — with import declarations, potential duty, and sanitary checks.

The Windsor Framework (February 2023, implemented from 2023–2025) fundamentally changed this approach:

Element	Northern Ireland Protocol	Windsor Framework
Approach	One rule for all goods	Differentiation: "at risk" vs "not at risk"
Customs declarations GB→NI	Required for every shipment	Only for "at risk" goods (Red Lane)
Duty GB→NI	Potentially applicable (EU rates for goods without rules of origin)	Zero for "not at risk" (Green Lane)
B2C parcels	Treated as commercial goods	Personal Package Limit — simplified procedures
Sanitary checks	Full EU SPS controls	Progressively reduced for Green Lane

The key principle of the Windsor Framework: goods that genuinely pose no risk of entering the EU market should not be subject to EU rules. This is a philosophical shift — from the automatic application of EU law to a risk-based assessment.

How the Green Lane works — the simplified route for GB→NI goods

The Green Lane is the preferential customs route for goods that are "not at risk" — goods destined solely for the UK market that will not enter the Republic of Ireland or the EU's single market.

Who can use the Green Lane:

For goods to travel via the Green Lane, they must be sent by a company registered under the UKIMS (UK Internal Market Scheme) or meet the criteria for private parcels (Personal Package Limit). Full details on UKIMS are covered in our article on the UK Internal Market Scheme.

What goods must satisfy to qualify for the Green Lane:

1. They must be destined for final recipients in NI (consumers or businesses operating in NI)
2. They must not be intended for onward export to the Republic of Ireland or the EU
3. They must be sent by a UKIMS-registered company or meet the criteria for private parcels
4. They must be correctly labelled — Green Lane parcels must carry a "UK Internal Market Scheme" marking or a clear indication of UKIMS status

What you gain through the Green Lane:

• No import declaration per shipment (consolidated reporting through UKIMS)
• Zero duty — even for goods that would otherwise attract EU tariffs
• Simplified sanitary checks for food and plant products
• Faster processing at NI ports (Belfast, Larne)

Red Lane — the full-check route for "at risk" goods

The Red Lane is the full customs procedure for goods at risk of entering the EU market — for example, goods in transit through NI to the Republic of Ireland, goods destined for sale in the Republic of Ireland, or goods sent by companies not registered under UKIMS.

What the Red Lane means in practice:

• A full import customs declaration on entry to NI (equivalent to an EU import)
• Duty at EU tariff rates (if UK goods do not satisfy TCA rules of origin)
• Full SPS (sanitary and phytosanitary) checks for food, plants, and animal products
• Longer port processing times

When goods are directed to the Red Lane:

• The company is not registered under UKIMS and has not submitted a "Not at Risk" declaration
• The goods are formally declared as intended for onward export to the Republic of Ireland
• The goods are subject to specific EU regulations (e.g. certain medicines and medical devices regulated by the EMA)
• HMRC or Border Force has grounds to believe that a "not at risk" declaration is incorrect

Personal Package Limit — rules for B2C private parcels

The Windsor Framework introduced a dedicated mechanism for private parcels (consumer parcels) sent from GB to consumers in NI. This is a separate arrangement from UKIMS — designed specifically for B2C traffic.

Personal Package Limit (PPL): Parcels below a specified value threshold, sent by a company or private individual from GB to a private consumer in NI, qualify for a simplified procedure without full customs formalities.

Key rules for PPL: - Parcels must be destined for a private consumer (not a business) - The parcel value must not exceed the threshold (the limit is subject to negotiation and updates — check the current HMRC guidance) - They must be labelled as "UK internal" shipments — with a GB sender address and an NI recipient address - Royal Mail and other postal operators have simplified procedures for PPL-qualifying parcels

Practical significance of PPL for B2C e-commerce: A company in England selling online and dispatching parcels to consumers in Belfast via Royal Mail or a courier can use PPL without UKIMS registration — provided the values and conditions are met. This significantly simplifies the handling of B2C orders to NI for small and medium-sized online retailers.

Changes for B2B: fulfilment to NI warehouses

For B2B trade (a GB company to a business or warehouse in NI), the position is more complex:

Fulfilment to NI warehouses — when Green Lane, when Red Lane:

Scenario	Route
GB company (UKIMS) sending to an NI warehouse (UKIMS) — goods to be sold to NI customers	Green Lane
GB company sending to an NI warehouse, goods subsequently exported to the Republic of Ireland	Red Lane
GB company without UKIMS sending goods to NI	Red Lane by default
Amazon FBA — goods from UK to Amazon warehouses in NI	Green Lane (Amazon holds UKIMS)

Not at Risk declaration for B2B: A GB company (UKIMS) sending goods to an NI business (UKIMS) may submit a "Not at Risk" declaration. Both parties must be registered and the goods must be intended for the UK market.

What else will change by 2026

The Windsor Framework is being implemented in phases. Some provisions came into force in 2024; others are scheduled for 2025–2026:

Changes already implemented (2023–2024): - UKIMS — registrations open, Green Lane operational - Personal Package Limit — in force for B2C shipments - Simplified SPS checks for the majority of Green Lane food products

Planned changes (2025–2026): - Express Parcel Facility changes — dedicated facilities for express parcels at NI ports (Belfast, Larne), intended to reduce processing times for courier shipments. - Further simplifications for medicines and medical devices — these categories are currently excluded from full Green Lane simplifications due to EMA regulations. - Digital Trade Documents — the introduction of fully digital commercial documents for GB→NI traffic, eliminating paper declarations. - Extension of the categories of goods qualifying for the Green Lane — EU-UK negotiations ongoing.

Note: The implementation timetable is subject to negotiation between the UK and the EU and may change. Always verify the current guidance at gov.uk/guidance/northern-ireland-protocol.

Practical implications for Polish companies operating in the UK

For Polish companies doing business in the UK (Ltd companies, fulfilment, e-commerce):

Scenario 1: Warehouse in England, customers in NI (B2C) If you are dispatching small consumer parcels, use the Personal Package Limit via Royal Mail or a courier. For higher volumes — register for UKIMS and use the Green Lane. Without UKIMS, every parcel technically goes via the Red Lane, with the risk of additional costs.

Scenario 2: B2B shipment from UK to a business customer in NI Register for UKIMS (your UK company). Ensure your NI customer also holds UKIMS or meets the "not at risk" criteria. Both parties must submit the relevant declarations.

Scenario 3: Import from Poland to UK, onward sale to NI Goods imported from Poland into England via a customs broker (UK import clearance), then dispatched to NI — may use the Green Lane via UKIMS. What matters is the place of dispatch (GB) and the company's status (UKIMS), not the country of origin of the goods.

Scenario 4: Transit through NI to the Republic of Ireland Goods passing through NI to the Republic of Ireland — always Red Lane, with full declarations and potentially EU duty.