Westminster Policy News & Legislative Analysis

Windsor Framework: SPS checks cut to 8%, customs IT access urged

The UK Government and European Commission confirmed a set of targeted adjustments following the Specialised Committee meeting on Wednesday 3 December 2025. Both sides restated their commitment to full and timely implementation of the Windsor Framework and recorded incremental progress since the previous session on 2 October 2025.

Sanitary and phytosanitary measures were the clearest change. The Committee welcomed a reduction in the frequency of SPS identity checks for consignments moving under the Northern Ireland Retail Movement Scheme from 10% to 8%, alongside improved delivery of permanent inspection facilities and steady uptake of labelling requirements. The reduction is contingent on accurate documentation and will only apply to compliant goods.

For retailers and food suppliers, the operational takeaway is administrative accuracy. Under government guidance, NIRMS consignments move on a single general certificate per load, supported by a packing list and pre‑notification to DAERA via a Common Health Entry Document. Any errors in seals, labelling or the certificate can trigger interventions that negate the benefit of the lower identity‑check rate.

Customs data sharing also advanced, though not yet to completion. Union representatives now have access to most UK IT systems, with both sides commissioning further technical work to deliver full access as a priority. Notably, the October statement had aimed for full access by 1 November 2025, indicating this remains a live delivery task.

This focus on systems follows earlier facilitation measures that took effect on 1 May 2025 for freight and parcel movements. Those changes were tied to a six‑month window to complete EU access to relevant UK systems, underscoring why closing the remaining gaps has become urgent for risk‑based controls and audit trails.

The Committee also highlighted the impending switch‑on of the Windsor Framework rules for veterinary medicines from 1 January 2026. UK guidance confirms that products “placed on the market” in Northern Ireland before that date may continue to flow, but new GB‑to‑NI supplies will need to meet EU‑aligned conditions, including batch testing on entry and release by an NI‑ or EU‑based Qualified Person.

Parliamentary evidence has further clarified packaging and authorisation requirements: the Marketing Authorisation Holder address shown on the pack must be in the EU or Northern Ireland from 2026. Government papers acknowledge sector concerns and set out support measures to protect animal health and continuity of supply. Firms should budget for relabelling, lead‑time effects from batch testing, and potential portfolio rationalisation.

Beyond goods movements, the Committee continued its examination of how the EU Artificial Intelligence Act and the Cyber Resilience Act intersect with the Framework’s operation. Under Article 13(4), newly adopted EU acts within scope can be added to the Framework’s annexes by Joint Committee decision; the Specialised Committee will report back at the next meeting. No additions were agreed at this session.

Timelines matter for compliance planning. The AI Act entered into force in 2024, with bans on prohibited practices applying from 2 February 2025 and obligations for general‑purpose AI models from 2 August 2025; wider duties phase in through 2026–2027. The Cyber Resilience Act entered into force on 10 December 2024, with incident reporting obligations from 11 September 2026 and full application from 11 December 2027, supported by Commission guidance and a single reporting platform.

The Committee also reviewed the work of the Joint Consultative Working Group and reiterated the need for sustained engagement with Northern Ireland stakeholders. In practice, the next quarter centres on three delivery points: bedding in the lower SPS identity‑check rate while tightening certificate compliance; finalising full EU access to UK customs IT; and preparing veterinary medicine supply chains for 1 January 2026 implementation.