Trading seafood with Northern Ireland | Seafish

Trading seafood with Northern Ireland

This guide provides essential information for businesses moving seafood between Great Britain (GB), Northern Ireland (NI), and European Union (EU).



In this guidance, "Great Britain" (GB) means Scotland, England, and Wales. "NI" means Northern Ireland, and "ROI" means the Republic of Ireland. 

Understanding the Windsor Framework 

The Windsor Framework is a trading agreement designed to ease the movement of goods between Great Britain and Northern Ireland after EU exit. This framework introduces a dual-lane system: 

  • Green Lane: For goods staying in NI, allowing simplified checks.
  • Red Lane: For goods at risk of entering the EU, requiring full EU customs procedures. More information on exporting seafood to the EU can be found on our EU/UK Regulatory Divergence Monitoring page.

Previously, moving goods between GB, NI and the ROI was straightforward, as all regions followed the same EU regulations. After EU exit, the UK and EU agreed the Windsor Framework, which facilitates trade while reducing paperwork, checks and duties. However, goods destined for the EU (including ROI) must meet full EU checks.

Moving Seafood from Great Britain to Northern Ireland  

If your seafood is staying in NI and will not enter the EU, it may qualify for the green lane (simplified checks) under the UK Internal Market Scheme (UKIMS).  

To use the reduced procedures, businesses must register with UKIMS. You can do so via the link below:

If your goods are in free circulation in Great Britain before moving to NI, the following applies: 

  • Export declaration.
  • Exit summary declaration.
  • Import declaration on arrival in Northern Ireland.
  • No customs duties to pay.
  • No VAT to pay at the point of arrival (domestic VAT rules still apply) 

For seafood businesses, it is important to ensure that the goods are not at risk of entering the EU to qualify for the green lane. Goods that are at risk of moving into the EU or destined for ROI will need to use the red lane, which includes full EU customs checks and procedures. 

For more information and to sign up for the Trader Support Service (TSS), visit the UK government website via the links below. The TSS provides free support for businesses navigating these rules. 

Moving Seafood from Northern Ireland to Great Britain 

Qualifying Northern Ireland Goods (QNIG) have unfettered access to Great Britain. This means that businesses moving seafood from NI to GB do not need extra checks or documents. This only applies if the goods do not come from outside the UK or EU. 

  • Requirements: No export declaration is required.
  • No exit summary declaration is required.
  • No import declaration is required on arrival in Great Britain.
  • No customs duties to pay.
  • No VAT to pay at the point of arrival (domestic VAT rules still apply). 

Goods that started their journey in the EU, even if moved through NI, may not qualify for unfettered access to GB. Rules of origin apply, and businesses should ensure compliance with these regulations. 

For more information, visit the government guidance page via the link below:

Moving Seafood from Northern Ireland to the EU 

Under the Windsor Framework, Northern Ireland follows EU VAT rules, allowing The protocol ensures goods can move without restrictions between NI and ROI, thus preventing a hard border. 

VAT treatment:

Health Certificates and Sanitary/Phytosanitary (SPS) Requirements 

Seafood products remain subject to sanitary and phytosanitary (SPS) checks. 

Red lane goods: When moving to the EU or ROI, goods will require full SPS checks and health certificates.  

Green lane goods: Goods moving  toNorthern Ireland will face fewer checks, but some products may still need health certificates  

For further information on these requirements, visit the UK government’s SPS controls webpage or contact the regulation team.  

Labelling 

Under the UK Internal Market Scheme (NIRMS), exterior packaging must show 'Not for EU' if entering NI via the green lane. Phase 3 of the NIRMS labelling regulations requires individual labels on all fish products. Phase 3 is planned to come into effect in July 2025. 

For further guidance, see labelling requirements information on the government website:

It is important to check that your commodities qualify for NIRMS. All GB origin products, all NI products processed in GB, and all EU origin products qualify for NIRMS. There are also other seafood commodities from the rest of the world that qualify, such as those with no SPS requirements, like tinned fish and fisheries products that come from countries specified in the EU IUU implementing regulations. 

For a full list of eligible goods, visit the Government webpage:

Business Address 

Seafood products sold in NI must include a NI or EU address for the food business. If the food business is not in NI or the EU, they must include the address of the importer, based in NI or the EU. The address cannot be a PO Box; it must be a physical address, although it does not need to be the place of manufacture. 

Contact Us 

For questions about the Windsor Framework, the Northern Ireland Protocol, or seafood regulation, please contact our Regulation team by emailing: regulation@seafish.co.uk

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