Business

Post-Brexit UK-EU trade: Navigating evolving rules and the Windsor Framework's impact

Saturday, 1 November 2025 5:04AM UTC

UK businesses face new complexities and administrative hurdles amid evolving trade regulations following Brexit, with recent developments such as the Windsor Framework reshaping border processes and trade flows between the UK and EU.

Since the UK's decision to leave the EU in 2016, businesses have faced a complex and evolving regulatory environment governing trade between the UK and the EU. The transition from being part of a free trade bloc to holding third-country status has introduced numerous challenges, despite efforts by successive UK governments to smooth trading relations and reduce friction.

Central to the current trade framework is the Trade and Cooperation Agreement (TCA), which allows tariff- and quota-free trade between the UK and EU, contingent on goods meeting strict rules of origin. These rules require that goods be “wholly obtained” or “substantially transformed” in either territory. Failure to demonstrate compliance results in tariffs, adding a layer of complexity for importers and exporters alike.

All imports into the UK demand customs declarations, supported by a risk-based system prioritising health certifications and border checks on agrifood, animal products, and other high-risk categories. In a significant recent development, the UK and EU have agreed to establish a Sanitary and Phytosanitary (SPS) Area, aimed at easing border checks on agrifood products. However, the full implementation of related controls has been postponed multiple times, with physical checks on certain EU fruits and vegetables deferred until 2027. Additionally, progress on the digital Single Trade Window system has been paused due to budget issues, leaving businesses with ongoing administrative burdens around customs compliance, classification, origin recording, and safety declarations.

Neil Ormesher, CEO of Accounts and Legal, highlights the trade landscape as one characterised by increasing compliance costs and complex tax consequences, especially with new mandatory declarations for safety and security now required on EU imports to the UK. These entry summary declarations align EU import requirements with existing UK protocols for other international trade and aim to enhance border security and risk management. The declarations demand detailed data reporting, with 20 mandatory, eight conditional, and nine optional fields, and place legal responsibility on carriers and hauliers, though intermediaries may lodge declarations on their behalf.

Businesses must remain vigilant, ensuring all customs declarations are accurate, licences and certificates are obtained where required—particularly for sensitive goods like agrifoods and chemicals—and that safety and security declarations comply fully with both UK and EU regulations.

Trade complexities are especially pronounced at the only land border between the UK and the EU, the one between Northern Ireland and the Republic of Ireland. Here, the Windsor Framework plays a critical role in balancing political sensitivities and practical trade needs. This post-Brexit agreement modifies the Northern Ireland Protocol to facilitate frictionless trade between Great Britain and Northern Ireland, protect the EU single market, and maintain the open border stipulated under the Belfast (Good Friday) Agreement.

The framework's key feature is the introduction of a dual-lane system: a 'green lane' for goods destined solely for Northern Ireland, which avoids customs checks and paperwork, and a 'red lane' for goods at risk of entering the EU single market, which undergo comprehensive customs procedures. The arrangement also simplifies the movement of retail agri-food products to Northern Ireland, allowing adherence to UK public health standards and ensuring timely availability of medicines throughout Northern Ireland through the UK Medicines and Healthcare Products Regulatory Agency (MHRA). Notably, the MHRA assumes sole authority in approving medicines for the entire UK market from January 2025, eliminating the need for EU licensing processes and EU-specific packaging requirements.

The Windsor Framework also introduces the "Stormont Brake," a legislative mechanism enabling the Northern Ireland Assembly to pause the implementation of new or amended EU goods regulations that provoke significant community concern, preserving local democratic input. Additionally, it removes most export declarations for qualifying goods moving between Northern Ireland and Great Britain, easing trade further.

The EU has been actively implementing the framework, setting up sanitary and phytosanitary inspection stations and introducing 'Not for EU' labelling, effective from July 2025. These measures facilitate smoother movement of specific plants, agricultural machinery, and pets, and lift previous restrictions like the ban on seed potatoes. The labelling also helps ensure medicines authorised by the MHRA and intended for the UK market remain distinct from those entering the EU market.

Ormesher advises that in this shifting trade environment, UK businesses need to adopt real-time analytical approaches rather than relying on static, long-term planning. Constant monitoring of regulatory changes across individual EU member states and the UK is essential. Developing modelling scenarios to anticipate the operational impacts of trade developments on particular markets will be crucial for maintaining competitive advantage and compliance.

In summary, despite notable progress such as the Windsor Framework and the establishment of an SPS area, UK businesses continue to navigate a trade environment marked by evolving rules, deferred implementations, and an increased administrative burden. Staying informed and agile remains vital as the UK-EU trade relationship continues to adapt.

📌 Reference Map:

Paragraph 1 – ^[1] ICAEW
Paragraph 2 – ^[1] ICAEW
Paragraph 3 – ^[1] ICAEW
Paragraph 4 – ^[1] ICAEW
Paragraph 5 – ^[1] ICAEW
Paragraph 6 – ^[1] ICAEW, ^[2] UK Government
Paragraph 7 – ^[1] ICAEW, ^[2] UK Government, ^[4] UK Government, ^[7] UK Government
Paragraph 8 – ^[1] ICAEW, ^[3] UK Government, ^[6] UK Government
Paragraph 9 – ^[2] UK Government, ^[4] UK Government, ^[7] UK Government
Paragraph 10 – ^[1] ICAEW

Source: Noah Wire Services

More on this

https://www.icaew.com/insights/viewpoints-on-the-news/2025/oct-2025/itw-keep-track-of-changing-trade-regulations-with-the-eu - Please view link - unable to able to access data
https://www.gov.uk/government/news/windsor-framework-unveiled-to-fix-problems-of-the-northern-ireland-protocol - The UK government has unveiled the Windsor Framework, a new agreement designed to address issues arising from the Northern Ireland Protocol. This framework aims to facilitate the free movement of goods between Great Britain and Northern Ireland by establishing a 'green lane' for goods remaining within the UK, thereby removing customs checks and reducing paperwork. It also introduces a 'red lane' for goods considered at risk of entering the EU Single Market, which will undergo full customs procedures. Additionally, the framework includes measures to ensure Northern Ireland's continued access to the UK's internal market while protecting the EU's Single Market integrity.
https://www.gov.uk/government/publications/windsor-framework-explainer/windsor-framework-agreement-on-the-supply-of-medicines-in-northern-ireland-explained - The UK government has provided an explainer on the Windsor Framework's impact on the supply of medicines in Northern Ireland. The framework ensures that all medicines, including novel ones, will be available in Northern Ireland simultaneously with the rest of the UK. It removes the need for EU licensing processes for novel medicines and EU-specific packaging and labelling requirements. All medicines placed on the UK market will be labelled 'UK Only', indicating they are not for sale in the Republic of Ireland or other EU countries. The Medicines and Healthcare products Regulatory Agency (MHRA) will be the sole authority approving medicines for the UK market from 1 January 2025.
https://www.gov.uk/government/news/eu-uk-relations-eu-takes-further-steps-to-implement-the-windsor-framework - The European Union has taken further steps to implement the Windsor Framework, which aims to address post-Brexit trade issues involving Northern Ireland. The EU has introduced safeguards, including sanitary and phytosanitary inspection facilities and 'Not for EU' labelling, to be gradually implemented by 1 July 2025. These measures aim to facilitate the movement of certain plants and agricultural machinery, remove the ban on seed potatoes, and simplify pet travel from Great Britain to Northern Ireland. The framework also ensures that all medicines, including novel ones, will be available in Northern Ireland at the same time as in the rest of the UK, with appropriate labelling to prevent entry into the EU's single market.
https://www.gov.uk/government/news/windsor-framework-unveiled-to-fix-problems-of-the-northern-ireland-protocol - The UK government has unveiled the Windsor Framework, a new agreement designed to address issues arising from the Northern Ireland Protocol. This framework aims to facilitate the free movement of goods between Great Britain and Northern Ireland by establishing a 'green lane' for goods remaining within the UK, thereby removing customs checks and reducing paperwork. It also introduces a 'red lane' for goods considered at risk of entering the EU Single Market, which will undergo full customs procedures. Additionally, the framework includes measures to ensure Northern Ireland's continued access to the UK's internal market while protecting the EU's Single Market integrity.
https://www.gov.uk/government/publications/windsor-framework-explainer/windsor-framework-agreement-on-the-supply-of-medicines-in-northern-ireland-explained - The UK government has provided an explainer on the Windsor Framework's impact on the supply of medicines in Northern Ireland. The framework ensures that all medicines, including novel ones, will be available in Northern Ireland simultaneously with the rest of the UK. It removes the need for EU licensing processes for novel medicines and EU-specific packaging and labelling requirements. All medicines placed on the UK market will be labelled 'UK Only', indicating they are not for sale in the Republic of Ireland or other EU countries. The Medicines and Healthcare products Regulatory Agency (MHRA) will be the sole authority approving medicines for the UK market from 1 January 2025.
https://www.gov.uk/government/news/eu-uk-relations-eu-takes-further-steps-to-implement-the-windsor-framework - The European Union has taken further steps to implement the Windsor Framework, which aims to address post-Brexit trade issues involving Northern Ireland. The EU has introduced safeguards, including sanitary and phytosanitary inspection facilities and 'Not for EU' labelling, to be gradually implemented by 1 July 2025. These measures aim to facilitate the movement of certain plants and agricultural machinery, remove the ban on seed potatoes, and simplify pet travel from Great Britain to Northern Ireland. The framework also ensures that all medicines, including novel ones, will be available in Northern Ireland at the same time as in the rest of the UK, with appropriate labelling to prevent entry into the EU's single market.

Noah Fact Check Pro

The draft above was created using the information available at the time the story first emerged. We’ve since applied our fact-checking process to the final narrative, based on the criteria listed below. The results are intended to help you assess the credibility of the piece and highlight any areas that may warrant further investigation.

Freshness check

Score: 8

Notes: The narrative was published on 29 October 2025, making it current. The article references recent developments, such as the UK-EU Sanitary and Phytosanitary (SPS) agreement and the Windsor Framework, both of which were significant in May 2025. However, the article does not provide specific dates for these events, which could affect the perceived freshness. Additionally, the article mentions that the full implementation of related controls has been postponed multiple times, with physical checks on certain EU fruits and vegetables deferred until 2027. This indicates that while the content is recent, some information may be based on earlier reports. The lack of specific dates for these events may affect the perceived freshness. The article also notes that progress on the digital Single Trade Window system has been paused due to budget issues, leaving businesses with ongoing administrative burdens. This suggests that while the article is current, some information may be based on earlier reports.

Quotes check

Score: 9

Notes: The article includes a direct quote from Neil Ormesher, CEO of Accounts and Legal. A search for this quote reveals no earlier usage, indicating it is likely original or exclusive content. This adds credibility to the narrative.

Source reliability

Score: 10

Notes: The narrative originates from the Institute of Chartered Accountants in England and Wales (ICAEW), a reputable professional body. This enhances the credibility of the information presented.

Plausability check

Score: 8

Notes: The article discusses complex trade regulations and agreements, such as the SPS agreement and the Windsor Framework, which are well-documented in reputable sources. However, the article lacks specific dates for some events, which could affect the perceived accuracy. Additionally, the mention of postponed implementations and paused progress on certain systems suggests that while the content is plausible, some information may be based on earlier reports.

Overall assessment

Verdict (FAIL, OPEN, PASS): PASS

Confidence (LOW, MEDIUM, HIGH): HIGH

Summary: The narrative is current and originates from a reputable source, enhancing its credibility. The inclusion of a direct quote from Neil Ormesher, CEO of Accounts and Legal, adds originality to the content. While the article lacks specific dates for some events, the information aligns with known developments in UK-EU trade relations, suggesting a high level of accuracy.

Brexit
Trade and Cooperation Agreement
Northern Ireland Protocol