Unlocking opportunities with Dual Market Access

Dual Market Access provides significant benefits for manufacturers based in Northern Ireland:

• Seamless access to UK and EU Markets: Northern Ireland manufacturers can sell their products to customers in both the United Kingdom and the European Union without the usual complexities of international trade. This means they generally don't need to worry about customs declarations, proving preferential rules of origin to avoid tariffs (as tariffs are typically not applicable for NI-EU trade), or meeting additional marking, labelling, or marketing requirements when selling into either market (for QNIG into GB and under EU rules into the EU).
• No need for EU Authorised Representative (AR) under GPSR: When trading consumer goods in the EU, Northern Ireland-based manufacturers are not required to appoint an Authorised Representative under the EU General Product Safety Regulations (GPSR). Their location within Northern Ireland already satisfies the EU's establishment criteria.
• Advantage over GB manufacturers: This puts Northern Ireland manufacturers in a favourable position compared to manufacturers in Great Britain. A GB manufacturer selling consumer goods into the EU (and Northern Ireland) must appoint an EU Authorised Representative/Responsible Person located in either the EU or Northern Ireland and include their contact details on the product. An AR acts on behalf of the GB manufacturer to fulfil specific legal duties outlined in a written mandate.
• Potential to Act as UK AR for EU Manufacturers (Limited Scope): If UKCA marking applies to products manufactured in or supplied into the Great Britain market, there will be specific obligations and responsibilities for compliance and a manufacturer may appoint an authorised representative in the form of an individual or company established in the United Kingdom (which means a Northern Ireland based individual or company could be appointed).  Whilst the requirement for an authorised representative is mandatory under some product legislation, in most cases, it is voluntary.  This will become tighter when the UK brings in its own GPSR. 
  
  Qualifying Northern Ireland goods have different arrangements when sold into GB market, meaning they don’t require UKCA mark and the UK has legislated to continue recognition of EU requirements, including the CE marking, indefinitely for a range of product regulations. This means businesses have the flexibility to use either the UKCA or CE marking to sell products in Great Britain.

Dual Market Access simplifies trade for Northern Ireland manufacturers, providing them with easier and less bureaucratic access to both the UK and EU markets, and in the case of the EU's GPSR, giving them an advantage over GB-based manufacturers.

Dual Market Access offers significant advantages for buyers located in Great Britain and the European Union when sourcing goods from Northern Ireland:

• Seamless purchases without customs or tariffs: Due to Northern Ireland's unique position with unrestricted access to both the UK internal market and the EU Single Market for goods, buyers in Great Britain and the EU can purchase from suppliers in northern Ireland without the usual customs procedures or tariffs on these transactions.

• No additional standards required: The UK Government's commitment to ensuring unfettered access for Northern Ireland goods to the UK market, coupled with Northern Ireland's alignment with EU goods standards, means that goods manufactured in Northern Ireland can be sold into both GB and EU markets without needing to meet additional UK or EU licensing, certification, marking, labelling, or legal marketing standards beyond those already applicable in Northern Ireland.

• Familiar transactions for EU buyers: For buyers based in the European Union, purchasing from suppliers in Northern Ireland largely remains the same as it was before Brexit. The processes and considerations are very similar to dealing with suppliers within the EU Single Market.

• Domestic purchases for GB buyers: Buyers in Great Britain can treat purchases from suppliers in Northern Ireland as fully domestic transactions, just as they would when buying from suppliers in England, Scotland, or Wales. This simplifies the procurement process significantly.

Dual Market Access makes Northern Ireland an attractive and straightforward sourcing location for both GB and EU buyers, eliminating many of the trade barriers that typically exist between different customs territories.

Dual Market Access has distinct implications for suppliers based in the European Union and Great Britain who are selling goods into Northern Ireland:

Dual Market Access for EU suppliers

EU suppliers should consider: 

• Familiar intra-community trade: Supplying goods from the EU to Northern Ireland is very similar to selling to customers in any other EU member state. EU suppliers do not face additional or different steps.
• No customs or tariffs: There are no requirements for customs declarations, and tariffs do not apply to goods moving directly from the EU to Northern Ireland.
• EU VAT rules apply: Value Added Tax (VAT) is managed under standard EU VAT rules.
• Protocol supersedes TCA: While Northern Ireland remains part of the UK, the arrangements within the Northern Ireland Protocol govern trade in goods between Northern Ireland and the EU, taking precedence over the Trade and Cooperation Agreement (TCA) that applies to trade between Great Britain and the EU.

Dual Market Access for GB suppliers

GB suppliers should consider:

• Administrative requirements: Due to the Windsor Framework and the Northern Ireland Protocol, commercial consignments moving from Great Britain to Northern Ireland are subject to administrative requirements. However, there are no export declaration requirements in Great Britain.
• Trader Support Service (TSS): The UK Government has established the Trader Support Service (TSS), a free service available exclusively to UK businesses. GB traders can use the TSS to help them complete the necessary customs declarations if they choose to do so themselves.
• Comprehensive support: The TSS is a complimentary digital service that includes the Northern Ireland Customs & Trade Academy. It aims to assist UK businesses of all sizes in navigating the changes that have been in place since 1 January 2021. The TSS helps traders and their carriers by generating declarations for goods moving from GB to NI using their data. It also provides education, advice on the Windsor Framework and Protocol, and contact centre support for issue resolution.
• Potential tariffs and mitigation: While tariffs may apply to goods at risk of entering the EU when moving from Great Britain to Northern Ireland, these can be removed or waived through UK Preferential Origin rules or the de minimis allowance. Businesses claim back EU customs duties paid on 'at risk' goods imported into Northern Ireland, as long as the goods were sold or used outside the EU through the Duty Reimbursement Scheme.
• Simplification for trusted traders: Since 1 May 2025, administrative requirements for GB to NI movements primarily focus on goods destined for or at risk of entering the EU Single Market. 'Trusted traders' authorised under the UK Internal Market Scheme who can self-certify that their goods are for sale or end-use within the UK only (and are therefore not at risk of entering the EU), and who can provide supporting evidence, are no longer required to complete import declarations, including supplementary declarations. EU 'third country' tariffs do also not apply to these internal UK deliveries.

Dual Market Access means EU suppliers face a familiar trading environment with Northern Ireland. GB suppliers can benefit from support mechanisms and simplifications for trusted traders to help with new administrative procedures.

Manufacturers considering setting up in Northern Ireland stand to gain significantly from the existing Dual Market Access. They can avail of the same seamless access to both the UK internal market and the EU Single Market for goods currently enjoyed by Northern Ireland's own businesses.

Here's a breakdown of the benefits for manufacturers from Great Britain, the EU, and the Rest of the World setting up in Northern Ireland:

For manufacturers from Great Britain:

• Unrestricted EU single market access: By establishing a permanent base in Northern Ireland, GB manufacturers gain unrestricted access to the EU Single Market for goods, the world's largest single market. This access comes without the need for customs declarations or meeting preferential origin rules to avoid tariffs on imports.
• Continued seamless trade with GB: They also retain their ability to trade seamlessly with their existing customer base in Great Britain.
• Automatic compliance with EU GPSR: Setting up in Northern Ireland automatically meets the establishment criteria under the EU General Product Safety Regulations (GPSR) when selling consumer goods into the EU. This means they do not need to appoint an Authorised Representative (AR) within the EU, a requirement for GB and rest of world-based manufacturers trading into the EU.
• Familiar UK tax system: As HMRC is the tax, payments, and customs authority in Northern Ireland (as in Great Britain), GB businesses will already be familiar with operating within these systems.

For manufacturers from the EU:

• Frictionless Access to the UK Market: By establishing in Northern Ireland, EU-based manufacturers gain frictionless access to the UK internal market, the world's fifth-largest economy.
• Familiar regulatory environment: Since Northern Ireland aligns with EU legal standards for goods, EU-based manufacturers will already be familiar with and compliant with these requirements.
• Unrestricted access for QNIG: Goods manufactured in Northern Ireland that meet the criteria for Qualifying Northern Ireland Goods (QNIG) have unrestricted access to the UK internal market without needing to meet any additional UK legal, licensing, certification, marking, labelling, or marketing standards.

For manufacturers from the rest of the world:

• Access to both UK and EU Markets: Establishing premises in Northern Ireland provides access to both the UK internal market (meaning frictionless trade with Great Britain) and the EU Single Market for goods. Northern Ireland uniquely offers unfettered access to both of these major markets.
• Access to EEA Countries: Goods sold into the EU Single Market from Northern Ireland can be labelled as UK(NI), which the EU recognises as meeting its member state requirements. This also satisfies the origin rules of the EEA Agreement, granting access to Norway, Iceland, and Liechtenstein, in addition to the UK and EU markets.
• Access to UK free trade agreements: As an integral part of the United Kingdom, businesses established in Northern Ireland that meet the applicable origin rules can access the UK's 39 active free trade agreements with 102 countries and territories worldwide, including agreements and deals with Australia, New Zealand, India, USA and the CPTPP.

Northern Ireland offers a compelling location for manufacturers worldwide, providing a unique gateway to both the UK and EU markets, along with access to EEA countries and the UK's extensive network of free trade agreements. This removes significant trade barriers and streamlines access to two of the world's largest economic blocs.