Agreed on 27 February 2023, the Windsor Framework sets out new arrangements for the movement of goods between Great Britain and Northern Ireland.
Born out of Brexit, this framework aims to ensure the smoother flow of goods by removing limitations on East-West trade, preserving Northern Ireland’s standing in the Union, and enhancing the democratic fairness of the Northern Ireland Protocol.
Here, we explain the agreement's relevance to the labelling of goods, including medicines (UK only), food (not for EU), and chemicals/hazards.
What Is The Windsor Framework Agreement?
The Windsor Framework was introduced to address concerns that emerged following the issuing of the Northern Ireland Protocol in January 2021.
This new agreement between the UK and EU allows for the freer movement of consumer parcels through Great Britain and Northern Ireland. Under it, traders don’t need to worry about customs declarations and any other paperwork, which was previously required under the Northern Ireland protocol.
Designed to simplify the movement of goods from Great Britain to Northern Ireland, the Windsor Framework established the:
- UK Internal Market Scheme (UKIMS) - an HMRC authorisation allowing for the movement of eligible goods from Great Britain to Northern Ireland under the “not at risk” classification (provided that such goods are transported to NI for sale or final use by UK consumers)
- Internal Market Movement Information (IMMI) - a simplified dataset reducing the amount of information that has to be submitted to the Customs Declaration Service (for goods classified as “not at risk”)
- Trader Goods Profile (TGP) - for support in the completion of the simplified dataset
When Will the Windsor Framework Be Implemented?
As a warehousing or shipping operative, you may well be wondering about when the agreement will come into place.
Events such as the general election had an impact on the rollout. However, businesses across Great Britain and Northern Ireland were advised to prepare for staged implementation from 1 May 2025.
Requirements for B2C and B2B Distribution
Different arrangements are specified under the Windsor Agreement depending on the parcel and the recipient. There’s also some variation in the processes that must be followed in distributing parcels to businesses and consumers.
The Windsor Agreement allows for the duty-free movement of consumer goods, without customs declarations or security requirements. Businesses can distribute consumer parcels with no need for UKIMS registration. However, there are weight limitations of 100kg per single package and 31kg for a package including multiple items.
For the distribution of B2B parcels, companies are eligible to sign up for the simplified internal market movements process. Provided UKIMS authorisation and “not at risk” classification, such goods may be moved with a reduced dataset and no duty.
Labelling Requirements Under the Windsor Framework
The Windsor Agreement also introduces clearer labelling rules than those of the Northern Ireland Protocol:
Medicines (UK only)
In the case of medicine, the Windsor Agreement makes a clear distinction between products entering the UK and EU markets. Precluding the onward movement of medicines with UK licensing to the EU, they also specify common requirements for medicine packaging and labelling in the UK.
As of 1 January 2025, all medicines distributed within the internal UK market must:
- Be supplied in a single UK-wide pack bearing a “UK-only” label
- Not include the serialisation safety features required on EU packs under the EU Falsified Medicines Directive (EU FMD).
Such rules will ensure the labelling of medicines shipped to Northern Ireland as UK Only, preventing distribution across the EU.
Clear and legible labels must be directly printed onto the packaging.
Food Products
The UK government proposed including the “Not for EU” labelling on food (including agri-food) products in January 2024. This would have meant all such products had to display the labelling, irrespective of whether they’d been produced in Great Britain or imported from abroad.
Following a consultation, the decision was made not to proceed with this labelling in October 2024. However, the UK government confirmed its intention to ensure the availability of goods in Northern Ireland, establishing the legal authority to apply labelling requirements more widely if further intervention is considered necessary in the future.
The Windsor Framework also specified the requirement for a range of additional food and retail goods to be individually labelled from 1 July 2025. This applies to some plant-based products, all pre-packed and sealed fruit and vegetables, high-risk food of non-animal origin, and some cut flowers (exemptions are listed on the Gov.uk website).
Chemicals and Hazardous Goods
The Windsor Framework also specifies that chemicals and hazardous goods for the UK market must follow the UK classification, Labelling and Packaging (CLP) Regulation, incorporating the UN Globally Harmonised System (GHS).
Such labels must include:
- Supplier information (such as the name and contact details of the supplier/importer)
- Substance name and/or identification number
- Nominal quantity
- Hazard pictograms
- Signal words (with “danger” for severe hazards, and “warning” for less severe ones)
- Hazard statements (highlighting the nature of the hazard, such as “fatal if swallowed”)
- Safety advice (indicating vital precautions, such as “wear protective gloves”)
- Digital contact information (replacing the physical telephone number in some instances).
The Windsor Framework includes some updates for chemicals moving into Northern Ireland from Great Britain and other markets. For instance, the UK’s Health and Safety Executive has been made responsible for the classification and labelling of chemicals for the GB and NI markets.
Implications for Warehouse and Shipping Operations
Warehouse and shipping operators are advised to review the relevant sections of the Windsor Framework, updating customs and shipping procedures as needed. This might mean the inclusion of more detailed product descriptions and commodity codes to ensure compliance with the new customs data requirements.
In following the specifications of the Windsor Framework, companies may see reduced customs paperwork, lowered shipping costs, and improved delivery predictability for greater customer satisfaction.
How Label Source Can Help
With our comprehensive range of high-quality shipping labels and warehouse identification products, we can help you meet the new rules of the Windsor Framework. Made from self-adhesive vinyl or paper as standard, our labels are compliant with UK, EU, and international regulations.
If you can’t find what you’re looking for on our website, then please get in touch - our customer service staff will do everything they can to help.
