Quick Guide to Trade Routes

Ireland and
Northern Ireland

GB and Ireland

GB and Northern Ireland

Ireland and Northern Ireland
Goods
Customs

As agreed in the Northern Ireland Protocol there will be no customs paperwork requirements for the cross-border traders.

VAT

The VAT treatment on the supply of goods, as well as the intra-community supply and acquisition of goods rules, applies when moving goods from Northern Ireland to Ireland. Northern Ireland businesses are required to complete EC Sales Lists ( a report that has to be sent to HMRC by VAT-registered businesses who sell goods and services to other businesses) when selling goods to VAT registered customers in the Ireland and Intrastat declarations. Ireland companies moving and supplying goods to Northern Ireland are required to report details of trade with Northern Ireland on the Intrastat system and VAT Information Exchange System (VIES).

Learn more by visiting the InterTradeIreland guide to customs.

Ireland and Northern
Regulations 
Food Labelling

Under the Northern Ireland Protocol, goods sold in NI will continue to follow EU rules for food labelling.

Food Business Operators (FBOs)

Under the Northern Ireland Protocol EU food law will continue to apply to and in Northern Ireland. Therefore, for food labelling purposes, the address of a FBO established in Northern Ireland will continue to be accepted as an EU address.

Country of Origin

Under the Northern Ireland protocol, EU Country of Origin rules are applicable for food placed on the NI market. Where EU Law requires an indication of a Member State in respect to country of origin, food businesses must ensure that where food has originated in Northern Ireland, such indications should be in the form “UK(NI)” or “United Kingdom (Northern Ireland)”.

Organic Product Logo

The EU has agreed to recognise UK as equivalent in relation to organics. This means businesses will be able to use the EU Organic logo on all organic food until 31st December 2023.

Nutrition-Related Labelling

Under the Northern Ireland protocol, EU legislation relating to nutrition-related labelling will apply in Northern Ireland.

Chemicals

Chemicals (substances or mixtures) placed on the market in Northern Ireland must continue to comply with the EU Chemicals Classification, Labelling and Packaging Regulation. It is essential that businesses in Northern Ireland/Ireland comply with both sets of regulations.

Sector Specific Regulation

There will be some changes regarding industry specific regulations. These regulations changes will largely be done on a profession by profession and country by country basis, so it is essential that businesses check with the relevant professional body in the country they are wishing to undertake work in.

Learn more by visiting the InterTradeIreland  guide to regulations.

Ireland and Northern Ireland
Services
Qualifications

The EU wide system of qualifications recognition no longer applies. However, the Irish and UK governments have pledged to have their regulators cooperate to continue to recognize qualifications granted in the other jurisdiction insofar as possible.

Establishing/structuring your business

Northern Ireland businesses will need to find out if they need to report new information to Companies House and businesses in Ireland whose group includes a UK incorporated company or branch should review the UK Government’s guidance on company registration changes.

Data

Businesses can continue to share data across the border as the UK’s data protection system continues to be based on the same rules that were applicable when the UK was a Member State of the EU.

VAT

The NI Protocol will not apply to the supply of services and NI will follow all UK VAT rules relating to services. Most services supplied between NI and Ireland should not see significant changes for most sectors in respect of legislation and guidance, however, there may be some changes in terminology and invoice references.

E-commerce

The UK’s implementation of the EU’s e-commerce package will only apply to supplies of goods in respect of Northern Ireland, so if you supply services to or from Northern Ireland, these will not count towards the distance selling threshold.

Public Procurement

The Northern Ireland protocol does not apply the EU procurement rules meaning that Northern Ireland is in the same position as the rest of the UK and the EU procurement rules will cease to apply. The Brexit deal has put in place new procurement guarantees which will continue to allow suppliers of goods, services and contractors for works to tender for, participate in competitions and be awarded public sector contracts. 

Learn more by visiting the InterTradeIreland  guide to services.

Ireland and Northern Ireland
People
Common Travel Area

Under the Common Travel Area (CTA), Irish and British citizens move freely and reside in either jurisdiction and enjoy associated rights and entitlements including access to employment, healthcare, education, social benefits, and the right to vote in certain elections.

Frontier Worker

A frontier worker (also called a cross border worker) is a person who lives in one country, but works in another country. For instance, if you live in the Ireland and work in Northern Ireland. Irish citizens do not have to apply for a UK Frontier Work Permit but can still apply. The entitlements of Irish citizens to live, work and to access other benefits in the UK are protected by the Common Travel Area. 

Immigration

If you are an Irish citizen and you want to continue living in the UK, you do not need to apply to the EU Settlement Scheme. Your rights to live, work and access public services in the UK are protected under the Common Travel Area arrangement. However, even though you do not need to apply to the scheme yourself, your family members from outside of the UK and Ireland will need to apply.

Learn more by visiting the InterTradeIreland  guide to people.

GB and Ireland
Goods
Customs

If you trade with GB you must submit electronic customs declarations and pay any tariffs to Irish customs using a customs software package. There are different requirements depending if you are importing or exporting goods. Alternatively, a customs broker, acting on your behalf, can submit the declaration.

VAT

If you supply services to or receive services from the GB, different place of supply rules for Value-Added Tax (VAT) on services apply. The place of supply rule to be applied depends on whether the customer is a business or a consumer. For business to business, the place of supply is the place where the business receiving the services is established. If you receive services from a company based in the GB after the transition period, in general, Irish VAT will be due on the services. If you provide services to a company based in the UK, in general, GB VAT will be due on the services. For supplies of business to customer services, in general, the place of supply is the place where the supplier is established.

Learn more by visiting the InterTradeIreland  guide to customs.

GB and Ireland
Regulations 
Food Labelling

If you import food from GB to Ireland you will need to comply with the requirements for placing imported food on the Irish market. Food from Ireland will need to be compliant with UK labelling rules from 1 October 2022.

Food Business Operators (FBOs)

Pre-packaged food and caseins (proteins) must have an EU or Northern Ireland address for the FBO, or an address of the EU or NI importer of the food on the packaging or food label. A GB address alone will not be sufficient. Similarly product on the GB market must have a GB address, although you can continue to use an EU, GB or Northern Ireland address for product sold in GB until 30 September 2022.

Country of Origin

From 1 October 2022, food from GB must not be labelled as ‘origin EU’. For products that require origin labelling e.g. honey and primary ingredients. SMEs in Ireland need know that the UK will no longer be EU for origin labelling. For example if you currently label your honey ‘blend of EU honeys’ where it contains EU and UK honey then the label will need to be changed to ‘blend of EU and non-EU honeys’.

Organic Product Logo

The EU has agreed to recognise UK as equivalent in relation to organics. This means businesses will be able to use the EU Organic logo on all organic food until 31st December 2023.

Nutrition-Related Labelling

The food business operator must ensure the presence and accuracy of the food information in accordance with the applicable EU food information law and any requirements of relevant national provisions.

Chemicals

The UK REACH and the EU REACH regulations will operate independently from each other. Companies that are supplying and purchasing substances, mixtures or articles to and from Ireland and GB will need to ensure that the relevant duties are met under both pieces of legislation.

Sector Specific Regulation

There will be some changes regarding industry specific regulations now that the UK has left the EU. These regulations changes will largely be done on a profession by profession and country by country basis, so it is essential that businesses check with the relevant professional body in the country they are wishing to undertake work in.

Learn more by visiting the InterTradeIreland  guide to regulations.

GB and Ireland
Services
Qualifications

The EU wide system of qualifications recognition no longer applies. However, the Irish and UK governments have pledged to have their regulators cooperate to continue to recognize qualifications granted in the other jurisdiction insofar as possible.

Establishing/structuring your business

Businesses in Ireland whose group includes a UK incorporated company or branch should review the UK Government’s guidance on company registration changes. Guidance on changes in companies registration procedures for Non UK companies is available from the UK Companies House. 

Data

The EU has formally recognised the UK’s data protection standards. This will allow the continued seamless flow of personal data from the EU to the UK. and is expected to last until 27 June 2025.

VAT

The current VAT treatment of supplies of services between Ireland and GB will not change.

E-Commerce

The eCommerce Directive will no longer apply to GB, for example, you should check where your service is based and check for new legal requirements.

Public Procurement

Suppliers in Ireland and the UK are entitled to participate in procurement competitions in the other state, in the sectors covered with guarantees of equal treatment.

Learn more by visiting the InterTradeIreland  guide to services.

GB and Ireland
People
Common Travel Area

Under the Common Travel Area (CTA), Irish and British citizens move freely and reside in either jurisdiction and enjoy associated rights and entitlements including access to employment, healthcare, education, social benefits, and the right to vote in certain elections.

Frontier Worker

A frontier worker is a person who lives in one country, but works in another country. For example lives in Ireland but works in Scotland. Irish citizens do not have to apply for a UK Frontier Work Permit but can still apply. The entitlements of Irish citizens to live, work and to access other benefits in the UK are protected by the Common Travel Area.

Immigration

There are no requirements for passport controls in operation for Irish and British citizens travelling between Ireland and the UK. Immigration requirements, as appropriate, will continue to apply to non-EU and non-UK citizens.

Learn more by visiting the InterTradeIreland  guide to people.

GB and Northern Ireland
Goods
Customs

You will need to make declarations and pay any tariffs due when bringing goods into Northern Ireland from GB. You will need to determine if your goods are  ‘at risk’ or ‘not at risk’ meaning they are subject to EU tariffs.  You can sign up for the free Trader Support Service which is a free government supportive programme to assist you to continue the smooth movement of goods between GB and NI.  Alternatively, a customs broker, acting on your behalf, can submit the declaration.

VAT

VAT continues to be accounted for by the supplier as it previously was on goods supplied between Northern Ireland to GB and GB to Northern Ireland. VAT also has to be accounted for when a business moves its own goods from GB to Northern Ireland, however, a business is not required to account for VAT on the movement of own goods from Northern Ireland to GB unless the goods are subject to an onward sale to its customer in GB.

Learn more by visiting the InterTradeIreland  guide to customs.

GB and Northern Ireland
Regulations 
Food Labelling

You may label food from Northern Ireland and sold in GB as ‘UK(NI)’, ‘United Kingdom (Northern Ireland)’ or ‘UK’.

Food Business Operators (FBOs)

From 1 October 2022, pre-packed food to be placed on the GB market will need a GB or Northern Ireland address.

Country of Origin

Food from GB must not be labelled as ‘origin EU’ from 1 January 2021. Food from Northern Ireland can continue to use ‘origin EU’.

Organic Product Logo

You must continue to use the EU organic logo on any organic food or feed produced in Northern Ireland. You will need to use the EU’s Trade Control and Expert System New Technology (TRACES NT) to moving organic food and feed from GB to NI and all your organic goods must have a certificate of inspection (CoI).

Nutrition-Related Labelling

The Protocol on Ireland/Northern Ireland means that EU legislation relating to nutrition related labelling, composition, and standards continues to be directly applicable in Northern Ireland. Businesses should note, however, that under the Protocol the Food Standards Agency (FSA) is not able to submit (1) applications for new nutrition and health claims for Northern Ireland. Businesses seeking to submit any of the above applications or scientific dossiers in respect to authorisation for the Northern Ireland markets should forward them to the European Commission. 

Chemicals

Northern Ireland remains within EU REACH. The UK use UK REACH, the EU REACH regulations will operate independently from each other.

Sector Specific Regulation

There will be some changes regarding industry specific regulations now that the UK has left the EU. These regulations changes will largely be done on a profession by profession and country by country basis, so it is essential that businesses check with the relevant professional body in the country they are wishing to undertake work in.

Learn more by visiting the InterTradeIreland  guide to regulations.

GB and Northern Ireland
Services
Qualifications

There is no change to qualifications between GB and Northern Ireland. 

Establishing/structuring your business

There is no change in establishing or structuring your business  between GB and Northern Ireland. 

Data

There is no change to data or GDPR between GB and Northern Ireland.

VAT

There is no change to VAT between GB and Northern Ireland. 

E-Commerce

There is no change to e-commerce to GB and Northern Ireland. 

Public Procurement

There is no change to public procurement between GB and Northern Ireland.

Learn more by visiting the InterTradeIreland  guide to services.

GB and Northern Ireland
People
Common Travel Area

Under the Common Travel Area (CTA), Irish and British citizens move freely and reside in either jurisdiction and enjoy associated rights and entitlements including access to employment, healthcare, education, social benefits, and the right to vote in certain elections.

Frontier Worker

A frontier worker is a person who lives in one country, but works in another country. For example lives in Northern Ireland but works in Wales. Northern Ireland citizens do not have to apply for a UK Frontier Work Permit but can still apply. The entitlements of Northern Ireland citizens to live, work and to access other benefits in the UK are protected by the Common Travel Area.

Immigration

Immigration requirements, as appropriate, will continue to apply to non-EU and non-UK citizens. 

Learn more by visiting the InterTradeIreland  guide to people.