Windsor Framework at three: Legal essentials for hauliers and logistics operators

Three years after agreement and formal adoption in 2023, the Windsor Framework has reached full operational maturity. Most GB–NI movements now travel via the green lane with minimal customs processes. Physical checks at ports are targeted, low-frequency, and intelligence-led, however certain risks remain, having moved upstream, from the quayside to the quality of your data, your documentation, and your customer declarations.

This article summarises where the Windsor Framework now stands, what the recent independent review means for the sector, and what operators should be planning for ahead of the next formal review point in 2027.

How the green and red lanes work in practice

The dual-lane customs model is the centrepiece of the Windsor Framework.

Green lane movements apply to goods destined solely for final use or consumption in Northern Ireland. Goods moved through this route are treated as not at risk of entering the European Union. Access is conditional on authorisation under the United Kingdom Internal Market Scheme and the submission of a reduced data set drawn from ordinary commercial information. For authorised traders, goods moved through the green lane are not subject to routine customs checks and do not require supplementary declarations, except where justified by risk analysis or intelligence.

Red lane movements apply to goods at risk of onward movement into the EU, including into Ireland. These goods remain subject to full EU customs declarations, sanitary and phytosanitary (SPS) controls, and, where applicable, EU customs duties. 

For most haulage operators carrying standard retail or consumer goods that remain within NI , the green lane is now the default route. In practice, compliant movements increasingly resemble domestic trade, with formalities completed digitally before arrival.

Key milestones reached: 2023–2025

October 2023 saw the UK Internal Market Scheme replace the earlier UK Trader Scheme expanding the scope of goods eligible for green lane treatment and widening business eligibility. The NI Retail Movement Scheme was also introduced. Identity checks on retail consignments were set at 10%, and mandatory "not for EU" labelling was introduced for certain agrifood products. 

During 2024, the Windsor Framework (Implementation) Regulations 2024 entered into force, SPS inspection facilities progressed towards readiness, and identity check rates were reduced to eight %. From September 2024, NI businesses gained the ability to import beef, lamb, and poultry tariff-free from around the world through UK Free Trade Agreements. These new arrangements were available alongside the UK Internal Market system.  

In December 2024, the NI assembly voted to give democratic consent to the continued application of the framework's core provisions for a further four-year period, providing regulatory continuity through to at least 2028. 

During 2025, the business-to-consumer parcels scheme came into force (1 May), identity check rates dropped to approximately five %, final SPS facilities at Belfast, Foyle, Larne, and Warrenpoint became operational (6 October), and the veterinary medicines grace period expired on 31 December, after which supplies to NI were required to comply fully with EU law.

On 16 December 2025, the UK government published its response to Lord Murphy’s independent review of the Windsor Framework, confirming acceptance of all sixteen recommendations. In relation to haulage and logistics, the UK government will look at all possibilities to reduce frictions for logistics and haulage businesses on an ongoing basis, continuing to monitor effectiveness of the available facilitations.

Looking ahead: The 2027 review and beyond

Several forward-looking governance mechanisms remain in play: 

• A review of the enhanced coordination mechanism on VAT and excise duties is scheduled to take place by 1 January 2027. This will provide a further opportunity for both the UK and EU to assess whether governance arrangements remain fit for purpose. 
• The next democratic consent vote by the NI assembly is required within the four-year period following the December 2024 vote meaning a further decision on the continued application of the framework's core provisions will be required in that period. 
• No fundamental structural change to the framework is anticipated before 2027. The focus during this consolidation phase is on governance, democratic oversight, and improving business confidence through the implementation of Lord Murphy's recommendations. 

What this means for haulage and logistics operators

UKIMS authorisation is essential. Without it, your movements default to the red lane with full EU customs requirements. Ensuring authorisation is maintained and that scheme conditions are met on an ongoing basis is a core compliance priority. 

Data accuracy is the new frontline. Enforcement is audit-based and data-driven. Consignment information, customer declarations and record-keeping must be robust and verifiable. 

Mixed loads require careful management. Where a single consignment contains goods with different risk profiles or final destinations, the compliance position becomes more complex and the risk of red lane reversion increases. 

A trusted haulier concept may emerge. The government has committed to exploring options for further friction reduction. Operators with strong compliance histories should monitor developments and position themselves to benefit from any new facilitation schemes.  

Our team advises haulage, logistics, and supply chain businesses on all aspects of Windsor Framework compliance from UKIMS authorisation and data governance, to managing mixed consignment risk and engaging with emerging policy developments such as the trusted haulier concept.  If you are moving goods between GB and NI and want to ensure your operations are compliant, commercially efficient, and positioned for future changes, contact our team today.

Date published: 8 September 2026