UK Government: Updates Guidance for Northern Ireland Goods Not At Risk EU

• Businesses must now register for the UK Internal Market Scheme, replacing the former UK Trader Scheme.
• The Customs Declaration Service (CDS) is now the primary system for declaring Northern Ireland goods not at risk EU from outside the UK and EU.
• Goods subject to commercial processing or with a significant EU-UK duty differential (3% or more) are automatically classified as "at risk."
• A 2 euro handling fee per item applies to "at risk" distance sales entering Northern Ireland from the EU.
• Mechanisms exist for claiming repayment or remission of EU duty paid on "at risk" goods, including waivers under State Aid limits.

Businesses engaged in moving goods into Northern Ireland from Great Britain (England, Scotland, and Wales) or from non-EU, non-UK countries are now required to submit detailed information about these movements to HMRC.

The UK government has recently issued comprehensive updates to its guidance concerning goods entering Northern Ireland, particularly focusing on the criteria for declaring them "not at risk" of onward movement into the European Union. A significant change mandates that businesses can no longer seek authorization under the previous UK Trader Scheme (UKTS); instead, registration for the UK Internal Market Scheme (UKIMS) is now compulsory for those moving goods into the region. This shift is central to the updated framework designed to streamline trade while maintaining the integrity of both the UK internal market and the EU's single market.

Further procedural adjustments include the removal of instructions for declaring goods "not at risk" via the CHIEF system when they originate from outside the UK and EU. Businesses are now directed to utilize the Customs Declaration Service (CDS) for these declarations, reflecting a broader migration towards modernized digital customs processes. The guidance also clarifies how to claim repayment for overpaid excise duty resulting from errors in the duty off-set mechanism, providing a crucial avenue for rectifying financial discrepancies. Additionally, new information has been incorporated regarding declarations based on expected outcomes, alongside enhanced details on rules of origin requirements and the application of preferential rates for goods entering Northern Ireland.

The updated guidance provides critical clarity on which goods are classified as "at risk" of entering the EU, thereby incurring specific duty liabilities. Goods deemed "at risk" are subject to the applicable EU rate of duty. A new provision specifies that distance sales moving into Northern Ireland that are considered "at risk" of entering the EU will incur a handling fee of 2 euros for each line item. Conversely, certain categories of goods are explicitly excluded from being declared "not at risk" and are automatically classified as "at risk," meaning the EU duty rate will apply.

These automatically "at risk" categories include goods destined for commercial processing where the stipulated additional requirements for a "not at risk" declaration have not been satisfied. Furthermore, goods entering Northern Ireland from countries outside both the EU and the UK cannot be declared "not at risk" if the applicable EU duty rate exceeds the corresponding UK duty rate by three percentage points or more. An online tool has been introduced to assist businesses in determining whether tariffs are due on goods brought into Northern Ireland from Great Britain, offering practical support in navigating these complex duty options.

Businesses engaged in moving goods into Northern Ireland from Great Britain (England, Scotland, and Wales) or from non-EU, non-UK countries are now required to submit detailed information about these movements to HMRC. For entities new to this process or those requiring additional assistance, the Trader Support Service (TSS) remains available to provide guidance and support, though a new digital platform for the service launched on October 20, 2026, with the previous platform closing on November 30, 2026. Alternatively, businesses have the option to engage third-party individuals or firms to manage their goods movements into Northern Ireland, offering flexibility in compliance strategies.

Crucially, the guidance also outlines mechanisms for reclaiming or deferring EU duties paid on "at risk" goods. A dedicated link has been provided for businesses to access instructions on submitting claims for repayment or remission of EU duty paid on "at risk" goods since January 1, 2021. Additionally, businesses may be eligible to claim a waiver, subject to de minimis State Aid limits, for import duties. These provisions underscore the importance of meticulous record-keeping and proactive engagement with the updated Northern Ireland Protocol updates to ensure compliance and manage financial obligations effectively.

Lawyers and compliance officers advising on trade with Northern Ireland must be aware of the updated guidance on declaring goods 'not at risk' of moving to the EU, including the transition to the UK Internal Market Scheme and new procedures for duty payments and repayments. Failure to comply with these updated customs and duty rules could lead to significant financial penalties or delays for clients involved in cross-border trade.

Source: Original reporting via GOV.UK guidance updates