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Brexit Questions and Answers

This page contains information and some frequently asked questions on Brexit and Northern Ireland. Please visit our other webpages for information on EU-UK governance structures, devolution, post-Brexit legislation, and for a timeline of Brexit events and important future dates. Get in touch if there are other Brexit matters you’d like us to cover here.

  1. What is the Windsor Framework?
  2. What are the implications of Brexit for medicines supply to Northern Ireland?
  3. How are veterinary medicines impacted by Brexit?
  4. Travel and migration: does Northern Ireland have freedom of movement with the EU?
  5. Student exchange: does Northern Ireland take part in Erasmus?
  6. Food and supermarket products: what is the impact of of post-Brexit arrangements?
  7. What does Brexit mean for trade and haulage?
  8. Law and policy-making: who decides which laws for Northern Ireland? What is the role for the Northern Ireland Assembly in post-Brexit arrangements?
  9. Do EU citizens in Northern Ireland have the same rights as before Brexit?
  10. Plants: What are the consequences of post-Brexit arrangements for Northern Ireland?
  11. Parcels: What are the consequences of post-Brexit arrangements for Northern Ireland?
  12. Pets: What are the consequences of the post-Brexit arrangements for Northern Ireland?
  13. Research and other EU programmes: does Northern Ireland still take part?
  14. What do people in Northern Ireland think about the post-Brexit arrangements for Northern Ireland?
  15. What is the Stormont Brake?
  16. What is an applicability motion?
  17. What is the Democratic Scrutiny Committee?
  18. What is the democratic consent mechanism?
  19. What is Article 2? What does Brexit mean for rights and equality protections?
  20. What are the outstanding issues?
  21. What is the new relationship between the EU and UK?
  22. What does the EU-UK Trade and Cooperation Agreement (TCA) mean for Northern Ireland?
  23. Is Northern Ireland represented at meetings of the EU-UK Trade and Cooperation Agreement and Withdrawal Agreement institutions?
  24. What is the review of the Trade and Cooperation Agreement?
  25. Is Northern Ireland in the EU?
  26. Is Northern Ireland in the EU single market?
  27. What is Retained EU Law? What happened to the EU law which used to apply in the UK?
  28. Can Northern Ireland participate in UK and EU Free Trade Agreements?

 

What is the Windsor Framework?

The Windsor Framework made changes to the Protocol on Ireland/Northern Ireland in a number of areas, following concerns from some businesses, politicians and the public about the special trading arrangements for Northern Ireland after Brexit. Unlike the rest of the UK, under the Protocol, certain EU single market regulations for goods applied in Northern Ireland. This made trade in goods from Great Britain to Northern Ireland more complex, as EU rules, procedures, and checks apply. This body of EU law still applies, but the Windsor Framework aims to make the trading arrangements smoother and more flexible, and provide for greater input from NI stakeholders and politicians on the rules which apply here.  

The Framework established different channels for goods moving from Great Britain to Northern Ireland. Goods which are for end use in Northern Ireland can move through the UK Internal Market Scheme, with simplified procedures. Read more on these arrangements. Goods which are considered at risk of moving into the EU single market (e.g. Ireland) must move through the red lane, where full checks and controls are applied. There are facilitations for supermarket foods entering GB from NI - read more about the arrangements for retail agri-food. There are also simpler processes for parcels, pets and plants moving from GB to NI. The Framework made changes to rules on medicines so patients in Northern Ireland can access the same medicines at the same time as the rest of the UK. The Framework also made changes to VAT rules for Northern Ireland, and clarified state aid provisions.

The Framework makes provision for the Stormont Brake, whereby 30 MLAs from at least two parties in the NI Assembly can notify the UK Government that they wish to stop the application of a replacement EU law. Read more about the Stormont Brake

The European Commission and UK Government agreed the Windsor Framework in principle on 27 February 2023, and it was formally adopted by the EU-UK Joint Committee on 24 March 2023.

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What are the implications of Brexit for medicines supply to Northern Ireland?

Under the Protocol, EU pharmaceutical law applied in Northern Ireland, which caused concern about the future supply of medicines from Great Britain to Northern Ireland. The Windsor Framework means that EU rules no longer apply to medicines placed on the market in Northern Ireland. The same medicines will be available in Northern Ireland as in the rest of the UK. The UK regulator, the Medicines and Healthcare products Regulatory Agency (MHRA), approves medicines for NI. Medicines must be labelled ‘UK only’. Pharmaceutical products manufactured in Northern Ireland can freely access the EU single market.

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How are veterinary medicines impacted by Brexit?

The Windsor Framework didn’t make any changes on veterinary medicines: as under the Protocol, Northern Ireland will have to follow EU rules on veterinary medicines. There is currently a grace period in place, which was extended until the end of 2025, and means supplies from GB to NI are not disrupted. The British Veterinary Association says Northern Ireland could lose access to 51% of the veterinary medicines it currently receives -  the requirements under EU rules to send products from GB to NI make it likely that companies would withdraw from the market.

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Travel and migration: does Northern Ireland have freedom of movement with the EU?

The UK no longer has freedom of movement within the EU. It has established its own immigration regime. As set out in the Belfast/Good Friday Agreement, people born in Northern Ireland may choose to have a British or Irish passport or both.

With an Irish passport, you can continue to exercise many EU rights, such as the freedom to live and work in EU and EEA member states. The rights of British passport holders will depend on the EU country’s individual immigration rules, and they will no longer have an automatic right to emigrate to an EU country. This does not apply to movement between Ireland and the UK, where the Common Travel Area enables British and Irish citizens to live and work in either country.

If you are travelling to the EU on a UK passport, it should have at least six months validity and be less than 10 years old. Visitors can stay in the EU for up to 90 days in any 180-day period. British citizens travelling from GB with a pet will need a vet certificate and relevant vaccines. To work in an EU country, UK citizens will need a work permit, in most cases.

The UK Government introduced a points based immigration system, which applies to everyone, including EU citizens, who previously had freedom of movement. There are new requirements for an Electronic Travel Authorisation: all individuals (except British and Irish citizens) will have to seek permission to travel to the UK in advance. This will also apply to tourists arriving into the Republic of Ireland who wish to visit Northern Ireland.

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Student exchange: does Northern Ireland take part in Erasmus?

The UK Government decided to no longer participate in the Erasmus+ programme after Brexit.  It introduced an alternative programme, the ‘Turing Scheme’, named after mathematician Alan Turing. In July 2023, the Irish Minister for Further and Higher Education announced the Irish Government has allocated €2 million to higher education institutions in Northern Ireland so that students in NI universities and educational institutions will continue to have access to the Erasmus scheme.

From 1 August 2021, EU students wishing to study in Northern Ireland had to have settled status in the UK or a student visa. This does not apply to students who are Irish citizens. 

School trips between the UK and EU are also more difficult post-Brexit because of immigration requirements. 

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Food and supermarket products: what is the impact of of post-Brexit arrangements?

Under the original Protocol certain products (e.g. chilled meat) would have been banned from entering NI from GB. This was resolved through the Windsor Framework: the NI Retail Movement Scheme (NIRMS) means food products for supermarkets, hospitality venues, schools, hospitals, wholesalers etc. (i.e. food for final consumption in Northern Ireland) can enter NI with fewer checks and controls. This food can comply with UK, not EU, food standards but EU animal and plant health rules still apply. Food manufactured in Northern Ireland has access to the EU single market (as well as the UK market). Certain food items which enter NI using the NIRMS are required to have labels stating ‘Not for EU’.

Labelling

The EU and UK agreed in the Windsor Framework to use ‘not for EU’ labels on some products as a safeguard to protect the EU single market: the purpose is to inform consumers that the products are only for sale to consumers in Northern Ireland. As the labelling regime comes into operation, the frequency of identity checks on these goods moving from GB to NI will be reduced.

  • Products such as prepacked meat and fresh milk had to be labelled since 1 October 2023.
  • From October 2024, all dairy products, such as UHT milk and butter, have to be labelled.
  • From 1 July 2025, all retail goods (except those sold loose), which are subject to official controls at border control posts, must be individually labelled.
  • The Government intends to apply some of these requirements across the UK from October 2024.

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What does Brexit mean for trade and haulage?

The Windsor Framework established two ways for goods to move to Northern Ireland from Great Britain. The red lane is for goods entering NI from Great Britain which are considered at risk of then moving into the EU single market (e.g. Ireland). Full EU customs and SPS checks and controls are applied.

Goods which are for end use in Northern Ireland can use the UK Internal Market Scheme, where there are simplified procedures. Traders won’t have to pay EU customs duties and from 30 September 2024, will have less paperwork to complete.

There are facilitaitons for retail agri-food (the products you buy in supermarkets), through the NI Retail Movement Scheme. The same food is now available in NI supermarkets as in the rest of the UK. Read more on the arrangements for supermarket food.

The system is based on data sharing, labelling, and monitoring, so the EU can safeguard its single market. Certain conditions must be met for traders to make use of the schemes.

Some businesses have raised concerns about groupage or mixed loads: some of these items may be able to make use of the easements, while others must use the red lane. The Government issued guidance on this.

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Law and policy-making: who decides which laws for Northern Ireland? What is the role for the Northern Ireland Assembly in post-Brexit arrangements?

Under the Windsor Framework, and previously the Protocol, Northern Ireland applies a list of over 300 laws relating to the EU single market for goods. This includes legislation on goods, agricultural production and marketing, SPS measures, VAT and excise on goods, state aid, and the single electricity market. The EU customs code also applies to goods entering Northern Ireland.

The Windsor Framework did not change this, but gave more flexibility in some areas. It seeks to give NI stakeholders and politicians greater input on the rules which apply here, through the Stormont Brake, applicability motions, the Democratic Scrutiny Committee, as well as new governance bodies.  

The original Protocol also made provisions for a vote in the Assembly on the continued application of certain EU single market laws – the ‘democratic consent mechanism’.

Brexit returned certain powers to Northern Ireland and the other devolved administrations in areas previously governed by the EU. This is limited given the scope of the Windsor Framework, but, for example, Northern Ireland can now legislate on financial support for farmers. Read more on Brexit and devolution

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Do EU citizens in Northern Ireland have the same rights as before Brexit?

The UK and EU reached an agreement which protects the rights of EU, EEA and Swiss citizens who were resident in Northern Ireland by the end of 2020 (and vice versa: UK citizens resident in EU countries). EU citizens living in Northern Ireland by 31 December 2020 had to apply to the EU Settlement Scheme to continue living here after 30 June 2021. This does not apply to Irish citizens who benefit from the Common Travel Area between the UK and Ireland. The Settlement Scheme allows EU citizens to stay and continue to work, study and access benefits and services in the UK.

After 1 January 2021 EU citizens need a visa to live in the UK. The UK’s point-based system applies to all immigrants to the UK and freedom of movement from EU countries no longer applies. There are several routes to immigrate to the UK: for skilled workers with job offers, a global talent scheme for highly-skilled scientists and researchers, and student visa routes for international students and graduates. Again, this does not apply to Irish citizens.

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Plants: What are the consequences of post-Brexit arrangements for Northern Ireland?

Under the Protocol, plants being moved from GB to NI had to comply with full EU SPS measures such as certifications, checks and prohibitions. Certain trees and seed potatoes from GB were banned. The Windsor Framework eased the arrangements for moving plants. The bans on seed potatoes and some tree species have been lifted. A new scheme, the Northern Ireland Plant Health Label, means the certification requirements and checks are simplified, and it’s less expensive to move plants. This is subject to certain conditions.

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Parcels: What are the consequences of post-Brexit arrangements for Northern Ireland?

Under the original Protocol, all parcels moving from GB to NI would be subject to EU customs declarations. However, this was not fully implemented: a ‘grace period’ was in place. The Windsor Framework means that business-to-business parcels moved from GB to NI by trusted traders will be able to use the UK Internal Market Scheme with simplified procedures. From September 2024, there is a new scheme for business-to-consumer parcels moved by authorised carriers with simplified customs processes. There are no additional requirements for consumers, but parcel operators will have to submit data to HMRC. There are no additional requirements for consumer-to-consumer parcels.

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Pets: What are the consequences of the post-Brexit arrangements for Northern Ireland?

Under the Windsor Framework, people travelling with their pets from GB to NI require a pet travel document, confirming that the pet is microchipped, and a declaration by the owner that the pet will not go to the EU. Pets moving from NI to GB and back to NI only have to be microchipped. Previously under the original Protocol, pets travelling from GB to NI would require a rabies vaccination, animal health certificate and tapeworm treatment. There had been concerns about these arrangements, especially for guide dogs, as highlighted by the NI Equality Commission and Human Rights Commission.

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Research and other EU programmes: does Northern Ireland still take part?

The UK no longer participates in Erasmus and some other EU programmes. It decided to participate in Horizon Europe, the EU research and innovation programme. There was a delay to joining Horizon, because of the dispute over the Protocol on Ireland/Northern Ireland.

The EU and the UK committed to continue the PEACE funding programme for Northern Ireland, a programme to “support peace and reconciliation and to promote economic and social progress in Northern Ireland and the Border Region of Ireland”. You can find more information on this topic on the website of the Special EU Programmes Body, which manages the funding.

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What do people in Northern Ireland think about the post-Brexit arrangements for Northern Ireland?

Queen’s University Belfast’s project on post-Brexit governance conducts regular polls on public attitudes towards the Protocol and Windsor Framework. It finds a wide range of views on Brexit and the Protocol/Windsor Framework. Many businesses welcomed the Windsor Framework as a joint solution to some of the issues they had been highlighting. However, some said its processes could be more burdensome than under the Protocol (as it operated with grace periods).

Polling company LucidTalk also carried out a survey following the agreement of the Windsor Framework, as did the Institute of Irish Studies at the University of Liverpool.

There is also a broad range of views among political parties in Northern Ireland. You can view statements from NI’s political parties by following these links: DUP, Sinn Féin, Alliance, UUP, SDLP, TUV, PBPA.

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What is the Stormont Brake?

Under the Windsor Framework, certain laws relating to the EU single market for goods apply in Northern Ireland. In the original Protocol, when this EU law was amended or replaced, it would automatically apply to Northern Ireland. The EU and UK agreed a new mechanism in the Windsor Framework - the Stormont Brake. Under the terms of the Stormont Brake, 30 MLAs from at least two parties in the NI Assembly can notify the UK Government that they want the “emergency brake” to be pulled on an EU law i.e. that they wish to stop the application of amended or replacement EU law in Northern Ireland.  There are restrictions on its use - the Northern Ireland Executive must be operational and the NI Assembly in regular session. UK Government legislation sets out the process for the Stormont Brake.

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What is an applicability motion?

Under the new arrangements in the Windsor Framework, the UK will not agree for new EU acts to be added to the Windsor Framework, and therefore to apply in Northern Ireland, unless the Assembly passes an ‘applicability motion’ with cross-community support. Legislation from the UK Government sets out this new role for the Assembly. However, if the UK Government views there to be ‘exceptional circumstances’ (including the absence of a functioning Assembly and Executive), or if the new law would not create a regulatory border between NI and GB, it can agree to adopt the law in the Joint Committee.

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What is the Democratic Scrutiny Committee?

The role of the Democratic Scrutiny Committee is to assist with the observation and implementation of the new procedures - the Stormont Brake and applicability motions - for amended or new EU law which may apply in Northern Ireland under the Windsor Framework. Following notification by the UK Government of replacement or new EU law, the Committee may scrutinise these laws, undertake inquiries and reports, and engage with stakeholders.

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What is the democratic consent mechanism?

The Windsor Framework, previously the Protocol on Ireland/Northern Ireland, contains a ‘democratic consent mechanism’. This means that after four years the Northern Ireland Assembly will vote on whether to retain Articles 5-10 of the Framework, which apply EU single market regulations and the EU customs code. If the vote passes with cross-community support, the next vote will take place after eight years. If the vote passes by a simple majority, the next vote will be in four years. If the Assembly votes not to continue the provisions, they will cease to apply after two years and ‘new arrangements’ will be put in place.  The first vote will take place before the end of 2024.

The mechanism was included in the original Protocol and is unchanged by the Windsor Framework. Read more on the democratic consent mechanism.

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What is Article 2? What does Brexit mean for rights and equality protections?

Under Article 2 of the Protocol (now called the Windsor Framework), the UK Government committed to ensuring that there would be “no diminution of rights, safeguards or equality of opportunity” (as set out in the Good Friday Agreement) as a result of the UK leaving the EU. This means, for example, that rights such as freedom of religion and political thought, and equal opportunity, must continue to be protected in Northern Ireland after Brexit. Some of these rights are underpinned by EU law.

A ‘dedicated mechanism’ was established to implement this commitment: the Northern Ireland Human Rights Commission and the Equality Commission for Northern Ireland are tasked with overseeing and reporting on the Article 2 commitment. The Commissions also work with the Irish Human Rights and Equality Commission on issues relating to the island of Ireland. The Commissions’ Annual Report of July 2023 raises concerns about how new UK laws could risk diminishing rights covered by Article 2.

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What are the outstanding issues?

The Windsor Framework did not resolve issues for veterinary medicines for NI. Some politicians have expressed concern about how the Stormont Brake will operate in practice, and academics have highlighted that it could potentially lead to ‘dual divergence’.

The Lords Sub-Committee on the Windsor Framework published a report on the Framework in July 2023. Businesses stressed, “in particular for the non-retail sector, the Windsor Framework will be more burdensome than the Protocol as it has operated to date with various grace periods and derogations.” It also set out concerns that the Windsor Framework could “undercut the competitiveness of Northern Ireland businesses”, and highlighted the potential implications of regulatory divergence between NI and GB.

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What is the new relationship between the EU and UK?

The EU-UK Trade and Cooperation Agreement covers a wide range of areas, including fisheries, trade in goods, services, law enforcement and judicial cooperation, energy, mobility, social security coordination, transport, and participation in EU-funded programmes. It also establishes governance arrangements, and commitments to ensure a ‘level playing field’ for fair and open competition. The Agreement does not cover foreign policy, external security and defence cooperation.

The UK is no longer a member of the single market and customs union: it no longer benefits from the EU’s ‘four freedoms’: free movement of people, capital, goods, and services. The UK no longer applies EU law (except in the case of Northern Ireland) and no longer makes financial contributions to the EU, except for its participation in some funding programmes such as Horizon Europe.

An overview of the new relationship:

  • Trade in goods: UK-EU trade in goods is now subject to customs formalities, sanitary and phytosanitary (SPS) checks, and rules of origin procedures. The deal gives zero tariff and zero quota access for UK goods: this means customs duties won’t have to be paid on qualifying exports (i.e. goods manufactured in the UK, or subject to sufficient processing there).
  • Freedom of movement: UK citizens can travel to the EU visa-free for 90 days in a 180-day period. Beyond this, a visa may be required. UK citizens no longer benefit from freedom of movement.
  • Trade in services: UK service providers no longer benefit from the EU ‘financial services passport’ i.e. automatic access to the single market. Professional qualifications will not be automatically recognised by EU Member States.
  • Programmes: The UK has decided to no longer participate in Erasmus and other EU programmes. It will pay to access some programmes such as Horizon Europe, the EU’s innovation and research programme.
  • Fisheries: a transition period of 5.5 years will see 25% of the value of EU catch in UK waters transferred to the UK fleet. Annual quotas will then be decided by the UK and EU: if the UK decides not to grant access to EU fishermen, the EU can retaliate and restrict access to the EU single market for fish exports.
  • Security: the UK no longer participates in EU agencies such as Europol, Eurojust, or has access to databases such as the Schengen Information System (SIS II). The UK will continue to cooperate with these agencies and the EU and UK will make arrangements to continue strong cooperation, and facilitate fast exchange of criminal record information, subject to data protection requirements.

More detail about how Northern Ireland is affected

Further information:

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What does the EU-UK Trade and Cooperation Agreement (TCA) mean for Northern Ireland?

Northern Ireland, under the Windsor Framework, has different arrangements for trading with the EU compared to the rest of the UK. NI remains aligned to the EU single market for goods. The TCA alleviates some of the new barriers between the EU and UK and therefore between NI and GB. The zero quota/zero tariff agreement on goods moving between the UK and EU reduced the issue of ‘at risk’ goods. However, some customs formalities still apply for goods moving from GB-NI, and there is no agreement on SPS equivalence which mean there are related checks at ports in Northern Ireland.

The agreement on security means that the EU and UK maintain some of their cooperation, but this is limited: the UK no longer participates fully in EU agencies and databases, however there are means to continue close cooperation and swift sharing of data. This is important for Northern Ireland, given the cross-border cooperation with Ireland on matters such as policing and security.

There are changes to trade in services. This isn’t covered by the Windsor Framework and means Northern Ireland is affected in a similar way to the rest of the UK. UK service suppliers no longer have the same right to offer services in the EU, and there is no longer free movement of people or mutual recognition of professional qualifications. There are also implications for data flows.

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Is Northern Ireland represented at meetings of the EU-UK Trade and Cooperation Agreement and Withdrawal Agreement institutions?

Yes. The First Minister and deputy First Minister have attended meetings of the UK-EU Joint Committee, which oversees the Withdrawal Agreement, including the Protocol/Windsor Framework. The UK Government made this commitment regarding NI’s representation in the ‘New Decade, New Approach’ agreement, and restated it in its command paper on the Windsor Framework. Officials from the NI Executive attend meetings of the Specialised Committees and the Joint Consultative Working Group (JCWG) as part of the UK delegation. You can read more about these bodies and previous meetings on our governance pages.

The First Minister and deputy First Minister also attended meetings of the Partnership Council, which oversees the Trade and Cooperation Agreement. Northern Ireland Executive officials attend meetings of the TCA Specialised Committees, which cover areas of devolved competence.

Members of the NI Assembly can attend the UK-EU Parliamentary Partnership Assembly (PPA) as observers, along with representatives of the Scottish Parliament and Senedd Cymru. The PPA is made up of members of the European Parliament and the UK Parliament. It exchanges views on the TCA and can make recommendations to the Partnership Council. Read more about the PPA.

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What is the review of the Trade and Cooperation Agreement?

The Trade and Cooperation Agreement (Article 776) states that the EU and UK will jointly review the implementation of the Agreement after five years (and every five years thereafter). The first review is due to start in May 2026. (The Trade and Cooperation Agreement was applied provisionally from 1 January 2021 and entered into force on 1 May 2021.)

There are differing views on how extensive the review would be, and whether the review can be used to improve and deepen the relationship with the EU. The EU has stated that the review “doesn’t constitute a commitment to reopen the TCA or to negotiate supplementary agreements…The TCA will simply not be able to recreate any kind of notion of the single market.” The UK in a Changing Europe has published a report on potential paths for the review of the TCA.

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Is Northern Ireland in the EU?

No. Northern Ireland and the rest of the UK left the EU on 31 January 2020. However, under the terms of the EU-UK agreements, special arrangements apply in Northern Ireland. Under the Windsor Framework, Northern Ireland remains aligned with EU single market rules for goods and therefore maintains access to this market.

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Is Northern Ireland in the EU single market?

The EU single market rests on ‘four freedoms’: free movement of goods, capital, services, and people. Northern Ireland maintains alignment with, and access to the EU single market for goods. However, it is not part of the EU single market for services, for example, and only certain areas of EU law apply in Northern Ireland: on goods, SPS measures, agricultural production and marketing, VAT and excise on goods, state aid rules, and the single electricity market. The EU customs code applies to goods entering Northern Ireland, but NI remains part of the UK customs territory and can participate in its free trade agreements.

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What is Retained EU Law? What happened to the EU law which used to apply in the UK?

Retained EU Law (REUL) refers to EU law (as it was on 31 December 2020) which was converted into UK domestic law by the EU (Withdrawal) Act 2018. This aimed to provide legal certainty in the immediate period following the UK’s exit from the EU. It is also sometimes referred to as a ‘copy and paste’ of EU law onto the UK statute book. The Government’s catalogue of retained EU law lists over 5000 pieces of legislation covering 300 policy areas.

The UK Government’s Retained EU Law (Revocation and Reform) Act was passed in June 2023. The Bill, as introduced, contained a “sunset” clause, whereby the majority of retained EU law would expire on 31 December 2023, unless preserved. Amid concerns about the uncertainty this could cause, and lack of scrutiny for Parliament, this was replaced with a schedule of almost 600 items of retained EU law, which were repealed at the end of 2023.

The Act gives UK and devolved ministers powers to revoke, replace and reform retained EU laws more easily. As of December 2023, it repealed directly effective EU law rights and obligations in UK law, ended the supremacy of EU law, and allows courts to depart from established EU case law. REUL has been renamed ‘assimilated law’. Until 2026, the Government must publish periodic reports on progress and plans to revoke and reform REUL.

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Can Northern Ireland participate in UK and EU Free Trade Agreements?

Outside the EU, the UK no longer has access to the EU’s Free Trade Agreements (FTA). The UK Government has ‘rolled over’ FTAs covering over 60 countries, which it had previously had access to as a member of the EU.

Under the Windsor Framework, Northern Ireland remains in the UK’s customs territory. The Framework states that NI should be able to benefit from, and be included in UK FTAs with third countries, “provided that those agreements do not prejudice the application” of the Framework. If, for example, the UK concludes a trade agreement with a third country which allows products to enter into the UK, which are prohibited by the EU single market, this could have implications for Northern Ireland’s participation in the agreement.

Under the Framework, Northern Ireland products do not count towards ‘origin requirements’ in EU Free Trade Agreements. This has implications for products partly produced in NI and exported by Irish companies. It is estimated that around 25% of NI goods imported into Ireland are by firms which export to countries with which the EU has an FTA. For the dairy and beverage sectors, the percentage of imports is 61%.

Read more:

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