UK Internal Market Scheme for goods into Northern Ireland

The UK Internal Market Scheme (UKIMS) is an HMRC authorisation that lets a business bring goods into Northern Ireland as “not at risk” of moving on into the EU, so the EU tariff is not charged even where it is higher than the UK rate. Goods coming from free circulation in Great Britain then bear no duty at all, provided they are for sale to, or final use by, end consumers in the UK and the importer of record holds the authorisation. Goods that fail the tests are “at risk” and pay the EU rate of duty.

Why does the “at risk” question arise at all?

Under the Windsor Framework, goods entering Northern Ireland from Great Britain or from outside the UK and EU are treated according to whether they are at risk of moving on into the EU. HMRC’s guidance sets out the outcome. At risk goods are charged the applicable EU rate of duty and go through the full customs process. Not at risk goods are charged no duty if they enter from free circulation in Great Britain, and UK duty if they come from a country outside both the UK and the EU, or from Great Britain when they were not in free circulation there.

Goods can be not at risk in two ways. The first depends only on the duty rates: goods from Great Britain are not at risk where the applicable EU rate is zero, and goods from outside the UK and EU are not at risk where the UK duty is equal to or more than the EU rate. The Customs Declaration Service checks those rates automatically and no UKIMS authorisation is needed, though any preference or relief claim must be included in the declaration. The second way is UKIMS itself, which is what a business needs where the EU rate is higher than the UK rate.

UKIMS is a customs duty scheme. VAT on the same movements follows separate rules, explained in VAT and goods in Northern Ireland.

What conditions must the goods meet under UKIMS?

HMRC’s guidance “Moving goods you bring into Northern Ireland as not at risk of moving to the EU” lists three conditions, all of which must be met:

• the goods are for sale to, or final use by, end consumers located in the UK (for goods arriving from a country outside both the UK and the EU, the end consumers must be in Northern Ireland)
• the importer of record for the movement is authorised under UKIMS
• the goods are not subject to an EU trade remedy

Some goods can never be declared not at risk. Goods entering from outside the UK and EU where the EU rate is more than the UK duty by 3 percentage points or more are automatically at risk, as are goods that will be commercially processed in Northern Ireland where the extra processing conditions are not met. If only part of a line item qualifies, the qualifying part must be declared as a separate line, with the at risk remainder on its own line.

What if the goods will be processed in Northern Ireland?

Processing means altering or transforming goods, or any operation other than preserving them or adding compliance marks, labels or seals. To move goods for processing as not at risk, the authorised business must meet at least one of these tests:

• annual turnover of less than £2 million
• importing sheepmeat, poultry or beef using UK tariff rate quotas from outside the UK and EU
• the goods are for an approved purpose: food for sale to end consumers in the UK; construction where the processed goods form a permanent part of a structure in Northern Ireland; directly providing health or care services in Northern Ireland; non profit activities in Northern Ireland with no later sale of the processed goods; or final use of animal feed on premises in Northern Ireland

For construction, health and care, non profit and animal feed, the importer or one subsequent entity may carry out the activity. HMRC’s example is animal feed sold to a farmer who is the last business in the chain and uses it in Northern Ireland. These extra tests apply only to goods that will be processed; other goods can still move as not at risk under the same authorisation.

Who can be authorised?

The applicant must be established in the UK. A business established in Northern Ireland, or with a fixed place of business there, must have its human and technical resources permanently present in Northern Ireland, keep its customs, commercial and transport records available there, and apply using an EORI number starting XI. A business established elsewhere in the UK must carry out its customs operations in the UK, keep its records accessible in the UK and have an indirect customs representative in Northern Ireland, such as the Trader Support Service. It can apply with a GB or XI EORI, and HMRC says to use the XI number if it has one. The difference between direct and indirect agents is covered in Customs agents: direct and indirect representation.

HMRC also checks:

• a good customs and tax compliance record over the 3 years before the application, with no serious or repeated infringements
• no record of serious criminal offences relating to the economic activity of the business or the people running it
• good financial standing, including not being subject to bankruptcy proceedings and having met customs and import tax payments over the previous 3 years
• a clear understanding of the scheme and the ability to give HMRC accurate information
• records, systems and controls suited to the size of the business that can show each consignment really is not at risk

What evidence must you keep for each consignment?

Evidence must be kept for every consignment moved as not at risk, for 5 years, at an address in the UK that HMRC can visit. HMRC lists invoices, VAT invoices, contracts and purchase orders, delivery receipts, consignment notes, proof of installation, electronic records and, where preference was claimed, proof of origin. The evidence is not sent in routinely; HMRC asks for it when it checks.

A business that does not control where its goods finally go can still use the scheme if it can make sure the conditions are met. HMRC’s suggested evidence includes a written and signed declaration from the customer that the goods will stay in Northern Ireland, evidence that the customer sells only from a physical retail outlet in Northern Ireland to end consumers, or contracts showing installation in the UK. HMRC’s own example is a wholesaler selling a chair for an office in Northern Ireland, capturing the customer’s confirmation in a signed declaration or its online sales terms.

How do you apply and then use the authorisation?

The application is made online. HMRC asks for the EORI number, details of directors and the people responsible for the goods (including date of birth, National Insurance number and address), the company number or Unique Taxpayer Reference, turnover for the most recent complete accounting period (or forecasts for a new business), the estimated number of not at risk declarations a year, UK premises HMRC can visit, the intended use of the goods and how the business meets the records and controls requirements.

If approved, HMRC sends a letter with a UKIMS authorisation number. It can only be used for goods moved on or after the authorisation date. Authorised businesses submit Internal Market Movement Information, a simplified dataset based on commercial information, instead of a full declaration, either directly or through an intermediary. An intermediary must be told that the goods are not at risk, given the authorisation number and the EORI number linked to it. HMRC must also be told about any change to the information in the application or any difficulty in complying.

How does this work in practice?

Illustration only. A wholesaler in Leeds holds a UKIMS authorisation and moves two consignments of chairs from free circulation stock to Northern Ireland. Assume the EU rate of duty on the chairs is 5%.

Consignment	Customer and evidence	Treatment
£40,000 of chairs	Belfast office fit out firm; signed declaration that the chairs will be used in its offices	Not at risk; no duty
£10,000 of chairs	Distributor that also sells to customers in the Republic of Ireland	At risk; EU rate applies, £500 duty

The wholesaler declares the two lines separately and keeps the signed declaration, invoices and delivery notes for 5 years.

What are the common mistakes?

• Declaring goods not at risk before the authorisation date. The authorisation cannot be used for earlier movements.
• Treating stock as not at risk when the buyer may sell it on into the EU. The test is final sale or use by end consumers in the UK, so the evidence must support that.
• Overlooking the processing rules. A business with turnover of £2 million or more that processes goods in Northern Ireland needs an approved purpose, or the goods are at risk.
• Not keeping consignment level evidence for the full 5 years, or keeping it somewhere HMRC cannot reach in the UK.
• Leaving errors uncorrected. If goods were moved as not at risk by mistake, HMRC says to apply for a voluntary clearance amendment for the underpayment. If an authorised business wrongly paid the EU rate, it may apply for a repayment, with its authorisation letter or email as proof; see Reclaiming overpaid import duty with C285. Businesses that properly paid duty on at risk goods may be able to claim a repayment, remission or a waiver within de minimis State Aid limits.

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Related Accountapedia entries

• VAT and goods in Northern Ireland
• Landfill Tax in England and Northern Ireland
• The VAT Capital Goods Scheme
• Internal audit vs external audit
• The VAT margin scheme for second hand goods

Sources

• GOV.UK: Apply for authorisation for the uk internal market scheme if you bring
• GOV.UK: Check if you can declare goods you bring into northern ireland not at

Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 24 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.