Robert J. Park · Dashboards

EU law and the Windsor Framework

Which EU laws apply in Northern Ireland, where the Stormont Brake has been tried, how NI rules reach businesses in Great Britain, and which Irish and European Commission consultations are open. As at 25 October 2026.

Days to the deforestation rules
66
30 Dec 2026: large and medium firms, and all wood products
Days to the UK–EU summit
26
20 Nov 2026: agri-food deal and ETS link expected
Days to the Brake deadline
11
5 Nov 2026: Union Customs Code recast. One Brake used so far, not applied
Consultations you can act on
8 of 18
Open now, where the EU law applies in NI

The tracker

Coming up#

Dates that change what applies, and where. NI means an EU rule reaching Northern Ireland under the Windsor Framework.

NovDecJan 2027FebMarAprMayJunJulAugSepOctNovDecJan 20285 Nov 2026: Stormont Brake deadline on the Union Customs Code recast (EU) 2026/21085 Nov20 Nov 2026: Summit: agri-food (SPS) agreement and emissions trading link expected on the table20 Nov21 Nov 2026: Plastic waste exports to non-OECD countries banned (Waste Shipments Regulation)21 Nov9 Dec 2026: Product Liability Directive transposition date9 Dec30 Dec 2026: EU deforestation rules apply to large and medium firms, and to wood products from all firms30 Dec1 Jan 2027: UK CBAM starts, covering the whole UK including NI1 Jan20 Jan 2027: EU Machinery Regulation applies20 Jan18 Feb 2027: Battery passport, QR code and removability rules18 Feb31 Mar 2027: Temporary zero rate of VAT on household electricity ends31 Mar30 Jun 2027: EU deforestation rules apply to micro and small firms30 Jun1 Jan 2028: New CLP label format, advertising and online-sales rules apply1 JanRed: applies in NI · Green: UK–EU · Black: GB or UK-wide. Hover a dot for the event; the list below has them all.
  • 5 Nov 2026NIStormont Brake deadline on the Union Customs Code recast (EU) 2026/2108
  • 20 Nov 2026UK–EUSummit: agri-food (SPS) agreement and emissions trading link expected on the table
  • 21 Nov 2026NIPlastic waste exports to non-OECD countries banned (Waste Shipments Regulation)
  • 9 Dec 2026NIProduct Liability Directive transposition date
  • 30 Dec 2026NIEU deforestation rules apply to large and medium firms, and to wood products from all firms
  • 1 Jan 2027UKUK CBAM starts, covering the whole UK including NI
  • 20 Jan 2027NIEU Machinery Regulation applies
  • 18 Feb 2027NIBattery passport, QR code and removability rules
  • 31 Mar 2027GBTemporary zero rate of VAT on household electricity ends
  • 30 Jun 2027NIEU deforestation rules apply to micro and small firms
  • 1 Jan 2028NINew CLP label format, advertising and online-sales rules apply

Sources: the tables below.

EU law that applies in Northern Ireland#

Selected laws for environment, carbon, products and goods. Each name links to the Assembly tracker or the official guidance.

EU lawTopicWho it affectsApplies in NI?Key dates for NIAssembly scrutiny or Brake
Deforestation Regulation (EU) 2023/1115 (EUDR)Forest-risk goods: cattle, cocoa, coffee, palm oil, rubber, soya, woodFood and drink processors; timber, furniture and paper; printers; anyone importing cattle, cocoa, coffee, palm oil, rubber, soya or woodYesLarge and medium firms 30 Dec 2026; micro and small 30 Jun 2027, except wood products already under the EU Timber Regulation (30 Dec 2026)Amendments 2024/3234 and 2025/2650: no inquiry; no Brake
Machinery Regulation (EU) 2023/1230MachineryMachinery makers, importers and dealers; agricultural and construction equipmentYesApplies 20 Jan 2027, replacing Directive 2006/42Amending act 2026/1744: inquiry report 27 Aug 2026
Batteries Regulation (EU) 2023/1542BatteriesBattery and e-bike sellers; electronics; vehicle dealers; waste operatorsYesLabels 18 Aug 2026; QR code, passport and removability 18 Feb 2027; due diligence 18 Aug 2027Amendment 2025/1561: no inquiry
Packaging and Packaging Waste Regulation (EU) 2025/40 (PPWR)PackagingEvery business that packs goods for the NI market; food and drink; retailPartly
Design, recyclability, labelling, substances and single-use restrictions. Not producer responsibility, deposit return, reuse or recycling targets
Applies 12 Aug 2026, phased to 2030 and 2040No inquiry (30 Jan 2025); no Brake
CLP revision (EU) 2024/2865Chemical classification and labellingChemical makers, formulators, distributors; cleaning products; paints; agri-suppliesYesNew label format, advertising and online-sales rules postponed to 1 Jan 2028 by 2025/2439The only Stormont Brake case so far: notified 20 Dec 2024, not applied 20 Jan 2025
Construction Products Regulation (EU) 2024/3110Construction productsBuilders merchants, manufacturers of construction products, contractorsYesApplies from 8 Jan 2026, alongside 305/2011 until 2040Inquiry report 23 Jan 2025; no Brake
Waste Shipments Regulation (EU) 2024/1157WasteWaste and recycling operators; exporters of plastic, metal and paper wasteYesMost rules from 21 May 2026; plastic waste exports to non-OECD countries banned from 21 Nov 2026Inquiry report 6 Jun 2024
F-gas Regulation (EU) 2024/573F-gasesRefrigeration, air-conditioning and heat-pump installers; cold chain; supermarketsYesIn force since 11 Mar 2024; product bans and quota cuts phased in to 2050Notified late; no inquiry decision; no Brake
Ecodesign for Sustainable Products Regulation (EU) 2024/1781EcodesignMakers and importers of energy-related and consumer products; textilesYesIn force 18 Jul 2024; product rules follow by delegated actNo inquiry (11 Jul 2024)
General Product Safety Regulation (EU) 2023/988Consumer product safetyEvery consumer-product seller and online marketplace supplying NIYesSince 13 Dec 2024—
Product Liability Directive (EU) 2024/2853Product liabilityManufacturers, importers and online sellers; software and AI productsYesTransposition due 9 Dec 2026Inquiry report 19 Dec 2024
Toy Safety Regulation (EU) 2025/2509ToysToy makers, importers and retailersYesApplies from 1 Aug 2030Inquiry report 22 Jan 2026; Brake window closed 29 Jan 2026 with no notification
Detergents and Surfactants Regulation (EU) 2026/405Chemical productsCleaning-product makers and distributorsYesAdopted 11 Feb 2026Inquiry report 26 Mar 2026
Vehicle circularity and end-of-life vehicles (EU) 2026/1738Circular economyVehicle makers, dealers, dismantlers and parts recyclersYesAdopted 8 Jul 2026Inquiry report 27 Aug 2026
Farmers in the food supply chain (EU) 2026/1739Agri-foodFarmers, processors and retailers in the food supply chainYesAdopted 8 Jul 2026Inquiry report 27 Aug 2026
Union Customs Code recast (EU) 2026/2108CustomsEvery business moving goods into NI from GB or outside the EU; parcel carriersYesAdopted 16 Sep 2026Inquiry report 22 Oct 2026; Brake window open to 5 Nov 2026
REACH (EC) 1907/2006ChemicalsChemical makers, importers and downstream usersYes
EU REACH in NI, UK REACH in GB
Ongoing—
EU Emissions Trading System, Directive 2003/87/ECCarbon pricingElectricity generators in NIPartly
NI electricity generators only. Other NI sites are in the UK ETS
Since 1 Jan 2021—
Single Electricity Market rules (Windsor Framework Article 9 and Annex 4)Wholesale electricityGenerators, suppliers and large energy users on the all-island marketPartly
The all-island wholesale market
Ongoing—

Sources: NI Assembly EU law scrutiny tracker; GOV.UK; DAERA; HSE.

Often assumed, but not applying in NI#

These are not in the Windsor Framework annexes, though NI firms can still be caught through EU customers.

EU lawApplies in NI?Why
EU Carbon Border Adjustment Mechanism (EU) 2023/956NoNot applied in NI. The UK CBAM covers NI from 1 Jan 2027
Corporate Sustainability Reporting Directive (EU) 2022/2464NoNot in the Windsor Framework annexes. NI firms are caught only through EU subsidiaries or EU turnover
Corporate Sustainability Due Diligence Directive (EU) 2024/1760NoNot in the annexes. Reaches NI firms through EU customers
Nature Restoration Regulation (EU) 2024/1991NoNot in the annexes
Water Framework and Habitats DirectivesNoNot in the annexes. NI keeps its own regulations; the NI Human Rights Commission argues Article 2 protects some pre-2021 standards

Sources: House of Commons Library; NI Human Rights Commission; Windsor Framework annexes.

Stormont Brake and new EU acts#

Every Brake case, every Joint Committee decision adding a new EU act under Article 13(4), and the main oversight events, oldest first.

Sources: NI Assembly; GOV.UK; Council of the EU.

How NI rules reach Great Britain#

Three kinds of effect: GB firms must meet EU rules to sell into NI; GB rules are moved towards the EU to keep goods flowing; or GB and NI run two regimes and firms carry both.

IssueKind of effectWhat it means in GBKey date
Product safety (GPSR)Selling into NIGB sellers into NI need a responsible person in NI or the EU on the productSince 13 Dec 2024
Deforestation (EUDR)Selling into NIGB firms moving cattle, soya, wood and other goods to NI must meet EUDR. Defra proposes a GB regime aligned with itNI from 30 Dec 2026; GB proposal 23 Jun 2026
Packaging (PPWR)Selling into NIPackaging sold in NI must meet EU design and labelling rules; GB has not decided whether to followNI from 12 Aug 2026
UK Internal Market SchemeSelling into NIAuthorised GB traders can declare goods "not at risk" of entering the EU and move them to NI with simplified information instead of a full customs declaration. Whether a shipment is at risk decides how much of this page applies to itSince 30 Sep 2023
"Not for EU" labelsGB follows the EULabels on food sent to NI shops. A reserve power (SI 2025/790) could extend them GB-wide product by productPower made 1 Jul 2025
Plant health import rulesGB follows the EUGB rules on tomatoes, peppers and ginger aligned with the EU so goods can still go to NI (SI 2026/458)Debated 2 Sep 2026
Chemical labelling (CLP)GB follows the EUHSE to change GB CLP so one label works UK-wide, in effect following EU changesResponse Feb 2026; law to follow
BatteriesGB follows the EUEU rules in NI; UK to consult on an aligned UK-wide regimeNI enforcement approved 15 Sep 2026
Agri-food (SPS) agreementGB follows the EUGB would follow EU food and plant-health rules as they change, removing most GB-to-NI checksTarget mid-2027; not yet agreed
Emissions trading linkGB follows the EULinking UK and EU ETS, with each side exempt from the other's CBAM. A deal was reported in October but not confirmedUK–EU summit 20 Nov 2026
REACHTwo regimesEU REACH applies in NI, UK REACH in GB. A GB firm cannot hold an EU REACH registration itself: it needs an EU- or NI-based registrant or only representativeOngoing
F-gasTwo regimesGB and NI quotas diverge; GB suppliers to NI must meet EU bansGap widens 1 Jan 2027
Machinery and tumble dryersTwo regimesGB continues to recognise CE marking for machinery, so EU-compliant machinery can still be sold in GB. New GB ecodesign rules ban vented and convector tumble dryers from January 2027NI applies the EU Machinery Regulation from 20 Jan 2027
Electricity VATTwo regimesA temporary zero rate of VAT on GB household electricity does not apply in NI, where EU VAT rules on goods apply. The UK is funding NI households instead this winter1 Oct 2026 to 31 Mar 2027
Parcel and low-value customs dutyTwo regimesA new EU customs duty on low-value parcels applies in NI, but GB-to-NI goods that are not at risk of entering the EU are exemptFrom 1 Jul 2026

Sources: NI Assembly Brexit and Beyond; GOV.UK; HSE; Welsh Government; Council of the EU; NI Business Info.

Open consultations: European Commission and Ireland#

Open on 25 October 2026, soonest first. "Yes" means the EU law in question applies in NI, so NI businesses have a direct stake.

ClosesConsultationBodyWindsor Framework scopeWhy it matters for NI
26 Oct 2026Waste: early warning report 2027European CommissionNoIreland's progress on waste targets; all-island waste markets
27 Oct 2026Chemicals: update of test methodsEuropean CommissionYesREACH applies in NI
27 Oct 2026Industrial batteries: performance and durability valuesEuropean CommissionYesBatteries Regulation applies in NI
27 Oct 2026"Diversify EU" trade instrumentEuropean CommissionPossiblyEU trade rules on goods apply in NI
28 Oct 2026Wildlife trade: import suspensionsEuropean CommissionYesWildlife trade rules govern NI imports
30 Oct 2026Wild Atlantic salmon fisheries from 2027Ireland: DCEENoMigratory salmon stocks cross the border; the Foyle and Carlingford are managed separately by the Loughs Agency
30 Oct 2026On-farm capital investments (TAMS 3), as reported by AgrilandIreland: DAFMNoBenchmark for NI farm investment schemes
3 Nov 2026EU ETS and Market Stability Reserve reviewEuropean CommissionPartlyNI power generators are in the EU ETS; other NI sites are in the UK ETS
4 Nov 2026VAT and the circular economyEuropean CommissionLikelyEU VAT rules on goods apply in NI, but not on services such as repair
6 Nov 2026Methane reporting templates, energy sectorEuropean CommissionNoAll-island gas supply chain
10 Nov 2026Gas transmission capacity network codeEuropean CommissionNoGas flows into and across the island
11 Nov 2026Animal disease contingency plansEuropean CommissionYesEU Animal Health Law applies in NI
13 Nov 2026Nitrates: RENURE for liquid digestatesEuropean CommissionNoManure, digestate, Lough Neagh and the NI biomethane strategy
16 Nov 2026Battery passport access rightsEuropean CommissionYesBatteries Regulation applies in NI
19 Nov 2026Electricity network tariff structure review, phase 1Ireland: CRUNoFeeds the all-island electricity market
20 Nov 2026EirGrid draft Transmission Development Plan 2026–2035Ireland: CRUNoGrid on the Irish side of the all-island system
14 Dec 2026Data centres: minimum performance standardsEuropean CommissionNoIreland's data-centre load on the shared grid
13 Jan 2027Plastic packaging with bio-based feedstockEuropean CommissionLikelyPackaging product rules apply in NI

Sources: European Commission Have your say; gov.ie; CRU; Uisce Éireann. The NI Assembly scrutiny committee had no open calls for evidence.

What changed

  • 25 Oct 2026: Published. Same evening: nine corrections after an independent fact-check (Customs Code Brake window to 5 Nov; plastic-waste export ban 21 Nov; EUDR wood-product date; VAT cut is temporary; REACH, machinery and single electricity market rows reworded; two weak sources replaced; one unverified consultation removed). Added: who each law affects, the kind of each GB effect, the UK Internal Market Scheme, parcel duty, the Murphy review, a glossary, filters and this log.

Updated every Friday by 5pm. Each update is logged here.

How to read this page

Windsor Framework
The 2023 UK–EU agreement that replaced the Northern Ireland Protocol. Its annexes list the EU laws on goods, customs, VAT on goods, animal and plant health, state aid and the electricity market that apply in NI.
Dynamic alignment (Article 13(3))
When the EU amends or replaces a listed law, the new version applies in NI automatically, unless the Stormont Brake is used.
New EU acts (Article 13(4))
An EU law that is new, not a replacement, applies in NI only if the UK and EU add it by a Joint Committee decision, normally after the Assembly passes an applicability motion.
Stormont Brake
Thirty MLAs from at least two parties can notify the UK Government that an amended or replacement EU law should not apply in NI. It must be a last resort, and the change must be significantly different and affect everyday life. The Secretary of State decides. Used once, on chemical labelling; not applied.
Democratic Scrutiny Committee
The Assembly committee that examines each amending or replacement EU act and can hold an inquiry. Its reports and the Brake deadlines are on the Assembly's EU law scrutiny tracker.
UK Internal Market Scheme and "not at risk" goods
Authorised traders moving goods from GB to NI that will not enter the EU use simplified information instead of a customs declaration. Whether goods are "at risk" decides how much EU customs law bites on a shipment.
NI Retail Movement Scheme
The simplified route for prepacked food and drink moving from GB to NI shops and caterers. Goods carry "Not for EU" labels.

Sources: The Stormont Brake (NI Assembly); UK Internal Market Scheme (Department for the Economy); Retail Movement Scheme (GOV.UK).

Caught between the two rulebooks?

I help Northern Ireland businesses work out which rules apply to what they make and where it goes, respond to consultations, and build a compliance register from pages like this one. Get in touch or see what I do.

About this page

A dated snapshot, checked on 24–25 October 2026 against the NI Assembly's EU law scrutiny tracker and Brexit and Beyond newsletters, GOV.UK, DAERA, the Council of the EU, the European Commission and gov.ie. "Not in the annexes" rows are my reading of the Windsor Framework annexes, not legal advice. Every link is to an official source except where a row says "as reported by"; the NI Assembly's Brexit and Beyond newsletter is used where a GOV.UK page could not be opened. Commission close dates are usually midnight Brussels time; check the consultation page before you rely on one. Nothing on this page is fetched or sent, and every table can be downloaded as CSV.

More dashboards: all dashboards. Related: CBAM Exposure Tracker.