00:00 Welcome everybody to this TSS podcast, this is Windsor Framework Unpacked: Answering Common Questions. I’m Shanker Singham, I lead for the Trader Support Service consortium on customs and trade policy. I have with me Doreen Crawford who is the Stakeholder Manager for the Trader Support Service with the Chartered Institute of Export and International Trade. And Simon Pettigrew who is the Head of Strategy and Stakeholder Engagement for Northern Ireland Customs at HMRC. We’ll kick off with a question for Simon just to give us an update on implementation of the Windsor Framework. So, Simon, tell us what’s about to happen.
00:44 Thanks Shanker. So, following the guidance that was issued in September of 2024, there’s been extensive preparatory work undertaken for the new arrangements for the movement of goods between Great Britain and Northern Ireland, and parcels and freight as set out within the Windsor Framework. And as a result, and subject to the relevant procedures, the new arrangements are planned to take effect from the 1st of May 2025. Doreen, in terms of that preparatory work, a lot of that is focused around UKIMS and a lot of questions we’re asked is, what is UKIMS? What does it mean? How could we use it? I wonder if it’s worth unpacking a little bit of that.
01:22 So, the UK internal market scheme, which again is, as you heard Simon say, is known as UKIMS. It is what it says on the tin, it is a scheme for the goods moving from Great Britain. That’s England, Scotland and Wales into Northern Ireland in the most cases. And if they’re staying in Northern Ireland, they’re staying within that internal market. So, they’re not for onward movement into the EU. So, we’ve introduced a trusted trader scheme to say that if you’re moving the goods into Northern Ireland and they’re going to stay there, well then, you’re going to get some benefits from that if you hold the authorisation for this scheme. And again, it’s an HMRC scheme. So, some of the things Simon that we get asked is the rules that regulate this, is it mandatory to hold this UK Internal Market Scheme to move goods into Northern Ireland?
02:27 So, it’s not mandatory to have a UKIMS authorisation to move goods into Northern Ireland, but UKIMS allows businesses moving goods into Northern Ireland to do so currently without having to pay any customs duty. So, it removes some of that fiscal burden of moving goods. And when the Windsor Framework arrangements are fully implemented, it will allow businesses to access some additional facilitations for moving those goods. That will include the Internal Market Movement Information, which is the reduced data set. It replaces the sort of full customs declaration that is required currently. And also the Traders Good Profile, which is the unique system that holds information of the goods that a business regularly moves. It will allow businesses to use that to pre populate some of the Internal Market Movement Information so it will allow businesses who are moving goods under UKIMS and are eligible to do so, to do that with fewer burdens as they do currently.
03:26 You mentioned it’s a trusted trader scheme which I think is an important observation.
From a trader perspective, if you’re moving stuff and you know it’s inside the UK internal market, you know the UKIMS scheme is a prerequisite for a lot of other things. You know the things that Simon mentioned and so it’s the first thing you need to think about. First thing you need to do. If you’re moving not at risk, sign up for the UKIMs and then everything else kind of flows from that. So, even if you’re not going to use the simplified process, you’re still going to want to take advantage of moving your goods without having to think about paying tariffs and all of those things.
04:04 Some of the things that we’re hearing at the moment is that, do you have to do a supplementary declaration if I’ve signed up for the UK internal market scheme? And I’m going to say yes, you do. But again, as Simon has said, you can benefit from the reduced data set. Or, as Shanker has said, you don’t have to take those benefits, but it does allow you to make those declarations as not at risk. Simon, one of the questions we get asked is, I don’t know if my business has signed up, or I’ve lost my letter. I know that it’s fine to contact HMRC to ask them and you will be able to tell them whether or not their business is signed up. Is that correct?
04:50 Yeah. So, if you’re ever uncertain of whether that has happened or you’ve lost the information you need, you can definitely contact HMRC. We have a customs helpline you can phone up that number and speak to directly, we also have a direct contact mailbox for any businesses that come through which allows business to contact us within the Northern Ireland Customs Policy Team directly and we can support any questions that you have around UKIMs, or anything else more generally around moving goods into Northern Ireland so very happy for anyone to come to us directly.
05:22 So just if you’re not sure, please get in contact with HMRC. Shanker, I want to ask you a question around the TSS, we haven’t really brought them up yet. So, a lot of people, when they’re filling in the application for this trusted trader scheme, it does actually ask you about the indirect representation being the TSS. Can you explain a wee bit what that means?
05:49 Yes. In fact, it’s a good question because a lot of the challenges people have, in fact pretty much most of the challenges people have on signing up and getting accepted as a UKIMS registered Trader, relates to that question that you just asked. So, one of the changes of UKIMS from the previous UK trader scheme is that you can be GB supplier and you can be registered on UKIMS. And actually, that’s an important point because you know, it’s not about your terms of trade, it’s about whether you’re the actual UKIMS registered person and you can be a GB sender to be that person. But if you are a GB supplier and you don’t have a Northern Ireland facility, that’s perfectly fine you can still be UKIMS, but you need to be using an indirect representative.
What’s called an indirect representative in customs language. What you need to know for these purposes if you’re on the TSS, the TSS is the indirect representative for you. So, what you do on the form is you fill that in, and you say that I’m using the TSS and that’s the indirect representative. And that covers that requirement, so then you should be good to go.
06:59 Thanks and that’s just a box ticking exercise within that form. One of the other things, thanks Shanker, that you just mentioned, there was some of the requirements around that and especially if you’re a GB supplier and you’re registered for UKIMS into Northern Ireland. And again, it’s part of the authorisation within the UK internal market scheme. It asks about record keeping and evidence that the goods are staying within Northern Ireland. So again, it’s a lot of people wonder what type of evidence they should hold, and how long they would have to hold it. So, just for that you have to hold it for five years and it can be things like your stock records and things like that, but you also need to be able to see where the goods have moved in and been declared not at risk. Simon, can you add some kind of examples of what types of evidence that the businesses can pull to prove that the goods remained in Northern Ireland?
08:04 Yeah. So, this is something we get asked pretty regularly as to whether types of evidence are sufficient and whether HMRC has a list of what evidence we would accept. I think that the first thing I would say is we don’t have a prescriptive list of evidence require to meet the eligibility of the UK internal market scheme. We’ve kept this open to be quite facilitative because it’s a new scheme and we want businesses to use the sort of processes and systems they have in place currently to allow them to meet that. As Doreen was touching on, the type of things that we can accept are if you are a retailer, for example, selling goods directly to consumers in Northern Ireland, your invoices to show that the goods coming into your store and then being sold from there would be definitely be sufficient, things such as if you are selling goods via online marketplaces like e-commerce or things like that, you can have terms and conditions or tick boxes to meet the sort of requirements. It could also be things like a written declaration from your customers to say that the goods are not going to be sold into the EU, so there’s various things that can be used. We’re very open to for business to use the information that they have in the systems and records they have in place to meet that rather than those giving a prescriptive list. But one thing I would just say just to add in is a bit of a top tip, when you were talking about your application form, when you are telling us what information you have and how you hold it in your systems, I would recommend that you are as thorough as possible in that application form to make sure HMRC has a good understanding of the information you have and how you’ll store that. That will make sure your application goes through smoothly and you won’t have a back and forth with HMRC trying to understand a bit more about your own record keeping.
09:52 Ok, that’s really helpful. And again, it’s understanding your business and what you have. You don’t have to reinvent the wheel, really here. One of the other things I think is really relevant right now, especially with the implementation date coming up with the post and parcels is say for example, I was a haulier, I know my customer has a UKIMS, so if I’m a haulier and my customer is sending goods, do I just guess that they’re UKIMS registered?
10:24 Well, there’s lots of ways here that that, that you can sort of have this conversation, and understand what the best way of moving goods is for you. And so, you know, one of the things Simon, first of all referred to the Trader goods profile, the so-called TGP. A trader can give permissions and authorisations for the haulier into their TGP. And that is helpful in terms of understanding for the haulier, who’s actually going to put in some data before the goods move across the boundary. I think it’s really important that you know, we talk a lot about supply chain conversations. But it’s really important you know what is happening to these goods that the supplier, the receiver, the haulier have all talked about what’s happening to these goods. Because one of the things that Simon mentioned was the use of the simplified processes. Well, if you’re going to do your Internal Market Movement Information. That piece of information that’s simplified before the movement, then obviously the haulier has to know that, they have to know that’s what you intend to do with the goods. So, the haulier has to be able to have access to that. It’s not only the supplier and the receiver that can be UKIMS, the haulier can also be UKIMS authorised, and so you may decide based on your supply chain conversations that that’s the easiest way for this whole thing to work that your haulier is going to be UKIMS authorised, they will be the person who is the person responsible for doing that simplified process before the goods move across the boundary. So, there are many ways of doing this, but the critical thing is that you start talking to each other about how that’s going to work.
12:15 So what I’m hearing here is that you need to talk to the supply chain. You need to understand the application form and what we have to hold on record and we need to understand who’s trusted Trader scheme is going to be used because they’re going to have to hold all the records and if you’re not sure if you have one, you can contact HMRC and they’ll confirm it for you. Ok. So, one of the main things that we have mentioned a couple of times during this conversation is that if you’re using the trusted trader scheme, the UK internal market scheme, that you can declare your goods not at risk. What does that mean?
12:58 The best way to think about this is, do you know that your goods are not at risk of going into the EU at the point at which they are going into retail. So, if I sell, if I’m in GB and I sell something to a Northern Ireland retailer and it’s sort of being sold in retail in Northern Ireland then and I have the requisite evidence for all of that, then it’s not at risk. And that not at risk is not defeated by the fact that, an Irish buyer happens to come in and buy stuff. So, I mean for example, Doreen, we’ve had a number of examples where people have said to us, look, I own a shop in in Newry, it’s on the border. Lots of people from Ireland come in and buy stuff from my shop. I get stuff from GB. Does that mean I’m at risk? Does that mean I’m not? What does it mean?
13:59 Yeah and that’s a really good one. And especially with the, the whole of Ireland coming into play there. So, if you’re in a retail shop, if you own a shop and you bring your goods in from the GB and can you use UKIMS? Well, the goods technically are being sold from the retail shop. Simon, can I say that those goods are being sold from a retail shop in Northern Ireland? Can I use UKIMS there? What do you think?
14:31 So, I think the answer would be yes if you. If you’re selling from a retail outlet to directly to consumers in Northern Ireland, then yes, you can use UKIMS. If you look at the legislation, it says that you can use UKIMS for goods that are for sale to or end use by consumers located in Northern Ireland. So, if you’re selling goods directly to consumers in Northern Ireland and that is happening in a physical, outlet in Northern Ireland, definitely you can use UKIMS. As Shanker touched on, it doesn’t matter if the person lives in the Republic of Ireland or lives in Northern Ireland, it’s where the physical sale of the goods happened.
15:07 We get this also with car dealerships for example. So, you know, it’s one thing to have a ham sandwich sitting in a in a shop in Newry, it’s another thing to have a car on a forecourt. So, Simon, Doreen, what do you think about? Suppose I’m a car dealer and I’ve got cars on my Northern Ireland forecourt intended to be sold to Northern Ireland customers. You know, how does that work, if occasionally an Irish buyer comes in? Or, you know there are lots of business models for these things, obviously.
15:40 So I think it goes back to the point you were making Shanker at the start. It’s the knowledge at the point of movement which is the important thing. So again, if you are bringing something in to be sold to a consumer from a location in Northern Ireland, I’d say that can moved under UKIMS and the type of good we’re talking about doesn’t really play into the differential there. So, it doesn’t matter if as a ham sandwich or a car if it’s been sold directly to consumer in Northern Ireland, then that can be move under UKIMS. If however, we’re talking about a car dealer who’s maybe been asked specifically to source a car for a citizen in the Republic of Ireland and the movement is being sourced directly for that person from Great Britain, for example, and you know it’s definitely going to Republic of Ireland that itself would likely be an at risk movement because you know at the point of movement the goods are not being sold to consumer in Northern Ireland, they are going directly to that person in the Republic of Ireland. So that’s the type of difference I would say in terms of how the knowledge at the point of movement impacts whether it can be at risk or not at risk.
16:52 Yeah, that’s all at risk of onward movement definition that we always hear. When can you not declare goods not at risk if they’re staying in Northern Ireland?
17:03 Great question and that’s a very timely question for the moment. So, there’s a set of categories of goods that can’t be declared not at risk. This was agreed by the EU and the UK early on in the in the process. So, if I’m receiving goods in Northern Ireland from the rest of the world and the difference between the EU tariff and the UK tariff is more than 3% then I can’t move those goods not at risk. The other category, the big category now is anything that’s subject to a trade remedy. So, a trade remedy is something like anti-dumping duty, a countervailing duty. So, it is worth, you know, making sure that the goods that you’re moving are not subject to some sort of anti-dumping measure, countervailing duty measure, safeguarding measure.
17:58 But don’t despair, because if you’re moving goods in Northern Ireland, they’re staying in Northern Ireland, and they are subject to these exemptions then you can use the duty reimbursement scheme so you can go to HMRC and you can claim back the tariff because the goods never left Northern Ireland and then finally the exemption is, you know, if you’re processing, if you’re a processor, you can’t be not at risk. But even if you are a processor, there are some exceptions to that rule for things like food and medical supplies, and some charitable things, construction materials, food and feed. And there’s also an exemption for a small processor. So, if my revenue is less than £2,000,000, then I’m going to be able to say I’m a small processor, I can still use the not at risk. So, it’s quite interesting, you know, a complicated set of rules, but you know, we’ve explained them in the TSS webinars and on the Northern Ireland Customs Trade Academy website.
19:11 Just to add in, Shanker, just on the point you were making there on the categories of goods, I think you’re right. You might need a bit of help to get your head around whether my goods are category one and maybe have to be declared at risk or category two or standard goods and what that means. There’s a couple of tools that we’ve developed in HMRC to help with that. So, we have the categorisation tool which links to the online tariff tool that takes you through a step-by-step process, looking through the commodity code and the country of origin, it can help you work out the category of your goods. The Trader’s Goods Profile that we’ve mentioned a couple of times also can help with that. So, if you have your Trader Goods Profile set up that can help you understand your category of your goods and as I say you can also contact HMRC directly if you’re a bit unsure on what to do. But if you are looking for a bit of assistance on how to categorise your goods, there’s definitely some tools there to help.
20:00 I know it sounds a little bit daunting with all these rules, but once you start using the tools, I think you’ll find that it’s a lot easier to manage than you might think at the at the outset. One final thing on this topic before we move to the next section is, Doreen, you know what if I’m moving both not at risk and at risk goods, what do I do? What’s my approach? If that’s the case.
20:23 We have two options. So, currently for the goods that you’re moving right now before there’s any change in the implementation of the Windsor framework which is proposed for the 1st of May, you can do a supplementary declaration and you can use the different lines on that declaration to declare goods at risk are not at risk on the same declaration. So, you can do that right now, nothing’s changing for that. Or once the new simplifications come in, you can split your goods into two different shipments and declare one with the reduced data set and that would be your not at risk goods. And again, you will be doing that with your UK Internal Market Scheme authorisation and keep all the supporting evidence and then you would also do an at risk declaration as well for the goods that you know that either you can’t declare not at risk, or they are at risk of moving on into the EU. So, two different options there. Or when the Windsor Framework implementation comes in, you don’t have to change to do the reduced data sent. As we said at the top of the call, this is all whatever suits your business right now within your business model. But the one thing you have to do is you have to understand that if the goods are remaining in Northern Ireland or in the internal market, you must be able to produce that evidence that they’ve remained. If you want to benefit from not paying that duty upfront.
22:00 Great. So, use of the simplified process as you said is optional and you it’s not like something is going to happen to you on May the 1st. You can continue to do what you’re doing and then decide to do it later on, depending on your business model, how you think about these things. One thing that is changing that isn’t optional, that is a mandatory change is the situation with respect to parcels.
So Simon, do you want to just give us a quick overview on what the changes are with respect to parcels coming up.
22:33 Yeah. Thanks, Shanker. So under the Windsor framework, the new arrangement for parcels will be determined based on whether the goods are moving direct to consumers or moving to a business.
So if we’re talking about movements that are direct to consumers, which would be either a consumer to consumer movement, a business to consumer movement or even a consumer to business movement, i.e. something’s been sent from an NI business to a consumer in GB and they’re returning it for any reason. Those goods will be able to move under a new UK carrier scheme, which was agreed under the Windsor framework. The UK carrier scheme is an authorisation in place for the people who are physically moving the goods, so that would generally be your parcel carriers, but it can be anyone else who’s involved in the physical movement of goods such as a haulier or a freight forwarder or anyone who’s involved in that movement of goods into Northern Ireland. And when those goods move under that scheme, that removes the requirements for any customs declaration, any duty, any safety and security declarations, and you would have to just provide the parcel carrier with standard commercial information as is pretty much what is in place now, and that allows those goods to move to consumers without the requirements for those customs processes.
23:57 In terms of the types of information that’s needed, if you’re a business sending it via partial carrier to a consumer in Northern Ireland, you would have to provide the name and address of who’s sending it, the name and address of who’s receiving the parcel, what’s in the parcel and that would be like a plain English good description of each item in the parcel, the total value and the total weight. All of which is pretty much similar to what happens now, and that removes any of the sort of custom processes to allow those goods to move. As I say, no customs declaration, and no duty and no safety and security declarations on goods moving under that route. One thing just to note is when you’re moving those goods through the port, there is still an interaction with GVMS. So, if you’re moving goods through a Ro-Ro port, for example, when you go into GVMS, all you’ll need is the EORI number of the authorised the UKC authorised business. So, if that’s the partial carrier or in your moving goods on their behalf, you would just need to get their EORI number that will allow you then to create the GMR and the goods can move. No further processes or anything like that in relation to consumer parcels.
25:05 There are a couple points just to note in terms of goods that can move through that route. So, there’s a couple weight limits. So, if you’re moving a parcel that contains a single item, it can weigh up to 100 kilograms. And if you’re moving a parcel that contains multiple items it can weigh up to 31.5 kilograms. So, anything within those weight limits going direct to consumers can move through that route without any of those customs processes that are in place just now for business to business movements. Anything above that, or if the parcel is actually going to a business, it would follow the similar processes that are in place for freight now. So, the things we’ve been talking about earlier around UKIMS, goods being at risk, not at risk apply to business to business parcels. An important thing to think about there in relation to both business to business and consumer parcels is make sure you’re speaking with your supply chain and in that sense what we mean is your parcel carrier. They will need to know whether the goods are going to a consumer or a business, and they’ll need to have the appropriate information. It’s worth noting if you’re moving business to business through a partial carrier, it’s likely part of their door to door service they will complete the customs paperwork on your behalf, so they may ask for things such as goods descriptions, commodity codes, UKIMS authorisation numbers, EORI numbers, when you’re either booking the movement, or whether you’re clearing that post movement. So, it’s important to make sure they have the appropriate information to move those goods. But as I say, to be clear, none of that is required for consumer movements. So you don’t need a UKIMS authorisation to move consumer parcels, it will just move through with the standard commercial information as is pretty much required now to allow any parcels to move into Northern Ireland.
26:58 I’m just listening to that Simon and I’m kind of like taking it in and going so if I’m sending a parcel now, and I’m Joe public, and it’s going to a consumer to a household in Northern Ireland, you’re telling me there that I don’t really need to do anything else bar go to my parcel operator and kind of give the same information I would have given before, my parcel operator’s going to handle everything else, yes?
27:24 Yeah, that’s right. So, in terms of what you actually need to do, the data is pretty much as is. The only thing that might be slightly different for some partial carriers depending on how they operate currently is a goods description for each good in the parcel. So some partial carriers may accept an overall goods description to describe it, such as gifts or something like that.
The only thing they’ll probably ask for now as a description for each good in the parcel.
So if you’re moving a multi item parcel where you’ve maybe ordered something from a clothing retailer and you’ve ordered a jumper, a pair of trousers and a pair of shoes, you’ll just need to give descriptions for the three items in the parcel, everything else is pretty much as is today.
28:08 And do I need to do that as a business as well? Give that kind of detail on the description of the goods?
28:14 Yes, so for business to business to consumer parcels, that information is needed, consumer to consumer parcels, it’s slightly less. We don’t ask for all of that information if you’re a private individual in GB sending that to private individual in Northern Ireland. So, what we’re talking about is if you’re a business sending goods to a consumer in Northern Ireland, you need to provide that good description of each item in the parcel.
28:37 And what do I do if I’m the haulier? So, I’m a haulier moving from a GB depot to a Northern Ireland depot, I’ve got parcels and I haven’t had to do anything before. I’ve just moved them before. What’s the change for me as a haulier?
28:51 So the change is really to understand who’s the authorised party moving those parcels. So again, as I said earlier, it probably will be a parcel carrier. So, one of our recognised parcel carriers, but it could also be yourself. So, if you’re moving goods on behalf of a parcel carrier, all you’ll need to know is for consumer parcels is the EORI number, and that will allow you to create GMR on that movement. If it’s for business to business, you will need to know how the parcel carrier will be clearing those. Whether that’s through EIDR for example, and you’ll need the EORI for the GMR or whether they are pre-lodging the customs declarations to allow you to do that on a GVMS as well.
The other thing as well is safety and security declaration will still be required on business to business parcels. So again, it’s just a good to understand like who’s going to actually take on the responsibility for that. Some parcel carriers will say we’ll take care of all of that as part of the end-to-end process, and let me just give you the relevant information that you need to create the GMR. Some may say to the haulier for example, you will need to create the S&S declaration. But I think I think the key thing there is if you’re moving parcels on behalf of a parcel carrier, it’s really important you speak with them, understand what they are doing and making sure that you’re as a haulier getting the right information, to allow you to move those goods into Northern Ireland.
30:14 Sorry Simon, what’s S&S?
30:18 Sorry, yes S&S. It’s one of those acronyms that we have, so S&S is a Safety and Security Declaration. So that’s what you’ll see now on TSS is that ENS, which in the Entry Summary Declaration that’s required for goods moving into Northern Ireland. So as I say, the processes that are in place for freight movements now will apply to B2B parcels as well when the new arrangements come into effect. And I think probably worth noting, there are quite a lot of acronyms that we have, so if you’re ever unsure there is a Jargon Buster on the NICTA website which may help with some of that and also in previous webinars, we sort of talked through and try and explain what these things are to make a bit easier to understand.
31:00 Ok. So, what I’m hearing here is that. Those supply chain conversations are really important. So, we talked about them at the very beginning of our chat and again, we’re still talking about them here. So have those conversations and decide if you’re going to use the UK Internal Market Scheme for businesses because it’s a business scheme to understand whose internal market scheme authorisation is going to record the goods. And then who’s going to collect all the records to support that movement. Is that fair to say here? Yeah.
31:35 Yeah, I mean, it’s a good point and a lot of the conversation that we just had about parcels, there’s a lot of data needed that people need to decide who’s got it, when they have it, when they give it to other parties in the supply chain. So, if you think about this in terms of data, you know, three of us here, if I’m the supplier and Doreen is the haulier and Simon is the receiver, the three of us need to get together and we need to decide. You know, maybe I’m the one who has the evidence that it’s staying in Northern Ireland. Maybe it’s Simon who has the evidence that it’s staying Northern Ireland, but we have to decide who’s going to be the UKIMS authorised person because that person is going to be the person who has to do the Internal Market Movement Information, the simplified process. So, I need to know whether I have the data to do that. Obviously, the haulier still has to do the, apologies for the acronyms, the ENS, the Safety and Security declaration. So, they need to know where they’re going to get the information from. If I’m doing the Internal Market Movement Information before the movement, then the haulier needs to know that. And so, I need to tell Doreen I’m the supplier, let’s say we’ve decided that I’m going to be the UKIMS authorised person. I need to tell Doreen the haulier. You know, this is what I’m going to give you before the before the movement so that you’ll be able to do what you need to do to get that information uploaded and so my goods can move through the through the boundary of Simon’s the UKIMS authorised person. He needs to have a conversation with the with the haulier to do all that but. Those conversations need to really need to have started already, but start them now. And again, remember, this is not a date on May the 1st, where you have to do all these things you can plan and use the optionality when it’s available to you whenever it suits you to do it. But those conversations are really important to have.
33:42 Yeah. So, parcels postal parcels is mandatory when implemented. We’re scheduled now, as Simon said, for the 1st of May and the rest are optional, yes.
33:57 Absolutely. That’s exactly right.
34:01 Yeah, just let you know we do have a Q&A session coming up. Please feel free to register for it if you want to come on, and ask your own individual questions, we’ll be there to answer them. And hopefully this has taken away some of those myths and provided some more facts around the basic questions.
34:19 Thank you very much and that’s the end of the Windsor Framework Unpacked: Answering Common Questions podcast.
