Trading seafood with Northern Ireland

Trading Seafood with Northern Ireland

This guidance outlines the regulatory requirements for businesses involved in the movement of seafood between Great Britain (GB), Northern Ireland (NI), and the European Union (EU), under the Windsor Framework and associated schemes.

Understanding the Windsor Framework

The Windsor Framework governs trade arrangements between GB and NI or through NI into the EU. It introduces a dual-lane system designed to facilitate the movement of goods while maintaining the integrity of both UK and EU markets. Goods that are intended to remain within Northern Ireland may move via the "green lane," which is subject to simplified customs and sanitary/phytosanitary (SPS) procedures. Goods that are considered at risk of entering the EU, including those destined for the Republic of Ireland (ROI), must move via the "red lane" and comply with full EU customs and SPS requirements.

Customs and SPS Controls: UKIMS and NIRMS

Businesses moving seafood from GB to NI must be aware of two distinct schemes that govern different aspects of the regulatory process. The UK Internal Market Scheme (UKIMS) addresses customs controls. Under UKIMS, goods that are in free circulation in GB and are not at risk of entering the EU may be declared as such, allowing them to benefit from reduced customs formalities and exemption from duties. Authorisation under UKIMS is a prerequisite for using the green lane.

To use the simplified green-lane arrangements you (or your nominated UKIMS-authorised trader) must be authorised under UKIMS, submit the required Internal Market Movement Information (IMMI) for each movement, retain supporting evidence (sales records, invoices and stock records) for five years and follow NIRMS labelling and general certificate rules where relevant.

See below for information on NIRMS:

In parallel, the Northern Ireland Retail Movement Scheme (NIRMS) governs SPS controls for agri-food products, including seafood. NIRMS enables eligible goods to move with reduced SPS checks and simplified certification requirements. To benefit from the green lane for seafood, businesses must be authorised under UKIMS and ensure that their products meet NIRMS eligibility criteria.

SPS Requirements and Health Certification

Seafood remains subject to SPS controls even where customs formalities are simplified. Many fishery products and live bivalve molluscs will still require registration on TRACES NT, pre-notification and an Export Health Certificate (EHC). There are narrow exceptions (for example, some direct landings by UK-flagged fishing vessels), always check the model EHC that applies to your product before shipment and pre-notify with the competent authority.

Labelling Requirements

Labelling obligations under NIRMS are designed to ensure compliance with EU market restrictions. Under the current Phase 3 labelling requirements of the Northern Ireland Retail Movement Scheme (NIRMS), all seafood products moved from Great Britain to Northern Ireland for final consumption must carry individual product-level labels stating “Not for EU”. This applies to fresh, chilled, frozen, and processed seafood, including composite products containing seafood. The labelling must be clear, durable, and visible on each retail unit.  unpackaged seafood sold in NI must be accompanied by appropriate retail signage to meet compliance standards.

Product Eligibility

Eligibility for NIRMS is determined by product origin and classification. Seafood originating in GB, EU-origin seafood imported into GB and subsequently moved to NI, and certain processed products such as tinned fish are generally eligible. Products from countries listed under the EU Illegal, Unreported and Unregulated (IUU) fishing regulations may also qualify. Conversely, seafood destined for ROI or other EU markets, live shellfish requiring full SPS checks, and composite products containing non-eligible ingredients are not eligible for movement under NIRMS.

As a result of changes to the EU’s IUU regulations, Northern Ireland Seafood businesses importing from GB or other non-EU countries are now required to use the CATCH system to fulfil their IUU documentation requirements. 

Movement from Northern Ireland to Great Britain

Seafood classified as Qualifying Northern Ireland Goods (QNIG) benefits from unfettered access to GB. These goods may move without the need for export or import declarations, and no customs duties or VAT are payable at the point of entry. However, goods originating from the EU or third countries may not qualify for this exemption, and businesses must ensure compliance with applicable rules of origin.

Movement from Northern Ireland to the European Union

Under the Windsor Framework, Northern Ireland continues to follow EU VAT and SPS rules. Businesses must use XI VAT numbers for transactions with EU customers and comply with full SPS requirements, including health certification. The framework ensures that goods may move freely between NI and ROI without the need for border checks, thereby maintaining the integrity of the all-island economy.

Business Address Requirements

Seafood products sold in Northern Ireland must include a valid business address. This must be a physical address located in either NI or the EU. Where the food business is not based in NI or the EU, the address of the importer must be provided. PO Boxes are not acceptable for this purpose.

Further Information

Businesses are encouraged to consult official government resources for detailed guidance on UKIMS authorisation, NIRMS eligibility, SPS controls, and labelling requirements. Support is also available through the Trader Support Service (TSS), which provides assistance with customs and regulatory compliance.