Windsor - help with identifying if goods are at risk or not

We are a UK company that imports goods from our parent company in Italy and an associated company in Germany. Most of our business is B2B, supplying components that are assembled into larger machines. Once sold, we have no control over where the final products end up—they could be used anywhere in the world. We’re struggling to determine whether our goods would be classified as “at risk” when moving them to Northern Ireland. Since we don’t manufacture in NI or have a presence there, we’re also unsure whether we need to register for the UK Internal Market Scheme (UKIMS). Additionally, we primarily use UPS as our courier, and we understand they can act as a customs representative. However, does that mean we still need to be UKIMS registered, or can they handle declarations on our behalf?

Hello, Hopefully the following will be able to help you :) Deciding ‘At Risk’ or ‘Not At Risk’ Step 1- goods subject to commercial processing are automatically ‘At Risk’, unless they meet some limited approved purposes. If not subject to commercial processing- move to step 2. Step 2- The applicable duties in EU • If the EU tariff has a zero rate of duty, the goods are ‘not at risk’. • If the EU tariff has a positive duty rate, move to step 3. Note- this is for movements from GB to NI only. Imports from the rest of the world to Northern Ireland are subject to different thresholds (see https://www.gov.uk/guidance/check-if-you-can-declare-goods-you-bring-into-northern-ireland-not-at-risk-of-moving-to-the-eu#when-you-can-declare-goods-not-at-risk) Step 3- UKIMS criteria Goods are ‘Not At Risk’ if ALL of the following are met; • Goods are for sale to, or final use by only end consumers located in Northern Ireland • The trader is authorised under the UK Internal Market Scheme • Goods are not subject to an EU trade remedy (anti-dumping duties, sanctions, countervailing measures etc) If all these criteria are not met (eg. the end user being in NI cannot be guaranteed, or the goods are subject to an EU trade remedy) the goods must be declared as ‘At Risk’. HMRC full guidance- https://www.gov.uk/guidance/check-if-you-can-declare-goods-you-bring-into-northern-ireland-not-at-risk-of-moving-to-the-eu Your customs representative/courier cannot register for UKIMS- it is you as the trader that needs to do this. You will need to tell UPS your UKIMS status, authorisation details and the risk status of each movement (some could be at risk, some may not be) if you are using Step 3 as the criteria to support the 'not at risk' treatment. If you are not established in Northern Ireland, you will need to use a customs representative that does have an establishment in Northern Ireland- you will need to name them on your UKIMS application, so check ahead of submitting that they are willing to do this. I hope this helps

Hi Andrew Cooke
If you move goods in or out of Northern Ireland the Trader Support Service will guide you through any changes due to the implementation of the Windsor Framework. 
You sign up for the Trader Support Service from the link at:
Sign up for the Trader Support Service
Thank you