Products moving between Great Britain and Northern Ireland are generally subject to one of two procedures.
If they are at risk of entering the EU Single Market, the products are subject to full EU customs and Sanitary and Phyto-sanitary procedures as laid out in the Official Controls Regulation (2017/625) (the so-called ‘red lane’).
However, if certain in-scope products are to stay in Northern Ireland (and hence stay within the UK) a different scheme applies under the Northern Ireland Retail Movement Scheme (NIRMS) (the ‘green lane’). Where applicable, these products are labelled ‘Not for EU’ on individual products. Where this is not required, the boxes containing individual products must be similarly labelled and signage is required in NI retail premises (e.g. on a shelf marker).
The ‘Not for EU’ labelling of individual products for the NI market has been rolled out in three phases. From 1 October 2023 it was required for meat packed for the final consumer, meat packed on sales premises and some dairy products. This was expanded on 1 October 2024 to include all milk and dairy products.
From 1 July 2025, the NIRMS requirements have been extended to include additional products including pre-packed and sealed fruit and vegetables, all fresh, frozen and processed fish, other products of animal origin (e.g. eggs), all chilled or frozen composite products, all shelf-stable composite products (unless specifically exempted), high-risk food of non-animal origin controlled under Regulation 2019/1793 and some cut flowers.
Details of the commodity codes for products that are in-scope and exempt can be found at – Commodity codes for the Northern Ireland Retail Movement Scheme (NIRMS) – GOV.UK
Mandatory ‘Not for EU’ labelling for products for the GB market was to be introduced on 1 October 2024 but that did not proceed. The Marking of Retail Goods Regulations 2025 were laid on 5 June 2025.These regulations give the Secretary of State the power to issue a notice requiring operators to individually mark specified products as ‘Not for EU’ before they can be sold to consumers in Great Britain. This will only be done if evidence shows that this is necessary to secure supplies across the UK internal market (i.e. supplies to Northern Ireland may be at risk).
This article is provided for information only and does not constitute legal advice. Formal legal advice should always be obtained before taking or refraining from taking any action.
Ian Thomas can be contacted at ian@ianthomasassociates.com
He also practises from Gough Square Chambers, London – ian.thomas@goughsq.co.uk