The fallout from Brexit continues to reverberate through the UK\u2019s internal market, particularly in trade flows between Great Britain (GB) and Northern Ireland (NI). More than five years after the UK\u2019s departure from the EU, stricter border controls and regulatory hurdles have contributed to a notable tumble in shipments, affecting retailers, manufacturers, and logistics firms. While the Windsor Framework aimed to streamline processes, recent data reveals ongoing challenges, with a new UK-EU agreement in May 2025 providing a glimmer of potential recovery. This article examines the latest statistics, sector-specific impacts, and emerging opportunities for improvement.<\/p>\n
The Windsor Framework and Its Intentions<\/strong><\/p>\n Introduced in February 2023 and phased in from October 2023, the Windsor Framework<\/a> sought to address frictions arising from the Northern Ireland Protocol by creating \u2018green\u2019 and \u2018red\u2019 lanes for goods moving from GB to NI. Green lane shipments\u2014deemed not at risk of entering the EU single market\u2014face minimal checks, while red lane goods require full EU customs compliance. This dual system was designed to preserve NI\u2019s unique position with access to both the UK internal market and the EU, often touted as the \u2018best of both worlds\u2019.<\/p>\n However, implementation has been bumpy. Parcel carriers must register as \u2018trusted traders\u2019 under the UK Internal Market Scheme (UKIMS), and businesses face increased paperwork, especially for business-to-business (B2B) movements. Some couriers have limited services to business-to-consumer (B2C) only, exacerbating delays. The \u2018Not-For-EU\u2019 labelling requirement, intended to prevent goods leaking into the EU, has been delayed and phased in gradually, adding to uncertainty.<\/p>\n Evidence of Continued Decline<\/strong><\/p>\n Data from the Office for National Statistics (ONS) Business Insights and Conditions Survey (BICS) underscores a persistent downward trend in GB-NI trade. Between 2020 and 2024\u201325, the proportion of GB businesses selling goods to NI fell from 5.7% to 3.9% overall. In manufacturing, it dropped from 20.1% to 12.9%, and in retail, wholesale, and repair of vehicles from 17.5% to 12.4%. Smaller firms have been hit hardest, with businesses employing 0\u20139 staff seeing a decline from 4.9% to 3.2%.<\/p>\n In the 12 months to April 2025, 15.1% of all GB businesses reported a decline in sales to NI, compared to just 6.2% noting an increase, while 8.3% stopped trading altogether. For retailers specifically, 14.2% recorded declines, 1.5% increases, and 11.4% ceased shipments. The percentage of firms citing the Protocol\/Windsor Framework as a trade challenge has risen in key sectors, such as manufacturing (from 11% in 2022 to 24.1% in 2024\u201325).<\/p>\n Broader UK trade figures reflect similar pressures<\/a>. Since Brexit, agrifood exports have fallen by 21%, and imports by 7%. Overall UK goods exports to the EU dropped sharply in January 2021 before partial recovery, but efficiency remains diminished due to customs and regulatory barriers. NI-specific data from the Northern Ireland Statistics and Research Agency (NISRA) for 2023 shows GB as NI\u2019s largest external partner, with NI exports to GB at \u00a317.1 billion (17.5% of total sales) and imports from GB at \u00a316.2 billion (26.1% of total purchases). Sea freight volumes included 9.2 million tonnes sent to GB and 10.2 million tonnes received, indicating steady but strained flows.<\/p>\n Retail, Logistics, and Manufacturing Under Strain<\/strong><\/p>\n Retailers and logistics providers have borne much of the brunt. Anecdotal evidence highlights practical hurdles, such as delays in shipping laptops or restrictions on sending Christmas hampers due to customs forms and specialist courier needs. Small and medium-sized enterprises (SMEs) struggle with interpreting guidance, leading some GB firms to avoid NI altogether to evade compliance risks.<\/p>\n In manufacturing, the rise in challenges cited (to 24.1%) reflects increased red tape for red lane goods, potentially diverting trade. Agrifood, a critical sector, has seen significant drops, with Brexit introducing rules of origin and checks that have permanently reduced efficiency. Trade diversion\u2014where NI firms source more from the Republic of Ireland or EU\u2014has emerged as a growing issue, complicating the internal UK market.<\/p>\n The May 2025 UK-EU Reset<\/strong><\/p>\n In a positive development, the UK and EU agreed on a \u2018reset\u2019 deal<\/a> in May 2025, including a new Sanitary and Phytosanitary (SPS) agreement to reduce red tape on food and drink trade. This could ease flows between GB and NI by removing routine checks on animal and plant products, potentially lowering prices and boosting choice. The deal addresses post-Brexit agrifood declines and is projected to add nearly \u00a39 billion to the UK economy by 2040. Additional measures, like linking emissions trading systems and defence cooperation, aim to foster broader stability.<\/p>\n Experts suggest this could substantially reduce the Irish Sea border\u2019s impact, allowing freer movement of goods like burgers and sausages. However, full benefits depend on smooth implementation, with calls for better guidance, a dedicated EU Economic Envoy for NI, and impact assessments on future policies.<\/p>\n Opportunities Amid Challenges<\/strong><\/p>\n While the decline dominate headlines, NI\u2019s dual market access remains a competitive edge, enabling free trade with both GB and the EU\u2014 a unique global position. NISRA data affirms GB\u2019s role as NI\u2019s top external market, with imports reportedly growing (reaching \u00a317.8 billion in 2023 according to some analyses). The Windsor Framework<\/a> has eased some administrative burdens, such as medicine supplies, and the reset deal could mitigate diversion risks.<\/p>\n Counterarguments highlight external factors, like global tariffs (e.g., potential US impacts), which could exacerbate NI\u2019s exposure to EU shocks. Overall UK trade has declined since 2019, with goods exports and imports down 13.2% and 7.4% by 2023, underscoring Brexit\u2019s wider toll.<\/p>\n Towards a More Fluid Internal Market<\/strong><\/p>\n Trade between GB and NI has undeniably tumbled under post-Brexit rules, with ONS data showing sustained declines in participation and volumes. Yet, the May 2025 reset offers a framework for reversal, emphasising reduced bureaucracy and enhanced cooperation. For businesses, clearer guidance and adaptive policies will be key to realising NI\u2019s dual-access potential and restoring pre-Brexit fluidity.<\/p>\n