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The United Kingdom has agreed with the European Union a new Brexit deal for Northern Ireland which seeks to significantly reduce the number of checks on goods going from Great Britain to Northern Ireland.

The Windsor Framework would create two ‘lanes’ for goods which are arriving in Northern Ireland from Great Britain:

  • green lane for goods remaining in Northern Ireland (for which there will be minimal checks or paperwork);
  • red lane for goods which might be sent onto the EU (which will still have checks).

Some product bans currently in place for goods entering Northern Ireland from Great Britain (for example on chilled sausages) will also be removed, and Northern Ireland will no longer apply EU VAT rules or alcohol duties on certain goods (e.g., immovable goods).

  • The same food will now be available on Northern Irish shelves as in the rest of the UK as UK public health standards will apply to food with end consumption in Northern Ireland.  “Not for EU” labelling will be introduced for certain higher-risk food products on a transitional basis.
  • There will be simplified procedures for imports of plants for planting and agricultural machinery from Great Britain to Northern Ireland.
  • New customs arrangements will allow goods being moved by trusted traders that are not at risk of entering the EU’s Single Market to move with dramatically simplified requirements, with all parcels now exempt from the main customs requirements (including business-to-business, business-to-consumer, and consumer-to-consumer).
  • Northern Ireland will now have access to all medicines, including novel medicines, at the same time as the rest of the UK as UK public health and consumer standards will now apply.
  • Identity checks will eventually be reduced to 5%, with physical checks following a risk-based approach.

The new framework also introduces the ‘Stormont Brake’ which will allow the Northern Ireland Assembly to object to new EU rules being enacted in Northern Ireland, if 30 Northern Irish politicians from at least two parties sign a petition.

The package of instruments agreed will be approved at the next meeting of the UK-EU Joint Committee (expected to take place in March 2023). The European Commission and UK Government must then translate this into legislation in order to implement the newly agreed rules.


Jennifer Revis is a partner in Baker McKenzie's London office and co-leads our EMEA Customs Team.
Jennifer focuses her practice on the public regulation of international trade, particularly in a wide range of customs compliance issues. She regularly advises clients on import matters, including customs valuation, rules of origin, and classification. She has worked with clients designing and implementing their compliance programs, policies, procedures and risk assessments, and assisting them in customs audits. She has significant experience in managing global customs projects and disputes, particularly in the area of customs valuation (transfer pricing; assists; royalties). Jennifer also advises on FTAs and trade remedies matters.
Jennifer has been consistently recognised as a "Leading Individual" for Customs & Excise and “Next Generation Partner” for Trade, WTO Anti-Dumping And Customs. Clients describe her as "an outstanding customs lawyer and litigator with fantastic experience. She is also easy to work with and leads her team with aplomb", "without a doubt, one of the best customs lawyers in the business (…) with an exceptionally deep knowledge of customs valuation concepts, as well as considerable experience applying those concepts in a variety of jurisdictions."
Jennifer has been on secondment to the UK customs authorities (Her Majesty's Revenue and Customs) in their tax and excise litigation department and to the Firm's European Law Centre in Brussels.


Johanna Asplund is an associate at the Firm’s London office in the Competition, Trade and Foreign Investment Practice Group. She completed her degree in International Relations from London School of Economics then a Graduate Diploma in Law and Legal Practice Course (LLM) from BPP University in 2019.


Rachel MacLeod is a senior associate in Baker McKenzie's London office. She advises companies on the "cradle-to-grave" regulation of a broad range of products sold on the EU and UK markets. She also advise companies on how to comply with their operational environmental and health & safety obligations.

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