Economy Minister Dr Caoimhe Archibald has welcomed long-awaited changes to the Duty Reimbursement Scheme (DRS) that aim to cut red tape for Northern Ireland businesses trading under post-Brexit arrangements. The modifications link the scheme with the Customs Duty Waiver Scheme and introduce flexibility for mixed stock claims, coming into effect this week after months of pressure from Stormont and industry representatives.
The DRS allows traders to reclaim EU customs duties paid on goods moved into Northern Ireland that never entered the EU single market—a critical facility under the Windsor Framework. However, businesses have struggled with complex evidence requirements and administrative burdens since the scheme launched in June 2023. The latest adjustments took effect on 25 May 2026, addressing these friction points weeks before a crucial deadline for backdated claims expires.
What is changing?
Amendments to the Customs (Northern Ireland) (EU Exit) Regulations introduce two optional facilitations designed to make the scheme more accessible:
- Linking waiver and reimbursement schemes: Businesses that previously used the Customs Duty Waiver Scheme (CDWS) can now apply to switch that relief to a DRS claim, potentially recovering duties more efficiently.
- Flexibility for mixed stocks: Traders handling pooled or interchangeable goods—common in manufacturing and retail—can now make claims without tracking each individual item, provided they meet evidence safeguards.
- Streamlined processes: HMRC has committed to reducing paperwork and clarifying data requirements, though specific operational details remain pending.
These changes follow recommendations from Lord Murphy’s Independent Review of the Windsor Framework, published in September 2025, which highlighted navigational challenges faced by businesses. The UK Government accepted all recommendations in December 2025, allocating £16.6 million to improve trade support services.
Minister presses for further action
Dr Archibald, who established a Tariff Working Group in April 2025 to monitor trade barriers including US tariffs, has consistently lobbied Westminster for these improvements. She described the pace of change as “frustratingly slow” but acknowledged the progress.
“I have been pressing the British Government consistently over the past year to act to improve the operation of the Duty Reimbursement Scheme, and while it has been frustratingly slow, I welcome that steps are being taken to address this.
I have been working collaboratively with businesses on this issue and will continue to do so. It is important that we assess the impact of these changes and highlight where further efficiencies can be achieved particularly around the applicable criteria, data and evidence requirements.”
— Dr Caoimhe Archibald, Economy Minister
HMRC will communicate directly with businesses about the new processes. The Minister’s Tariff Working Group—comprising representatives from NI Chamber, Logistics UK, Manufacturing NI and the CBI—will continue to monitor how effectively the changes reduce administrative burdens.
Critical deadlines approaching
While the new facilitations offer longer-term flexibility, businesses face an immediate cut-off. Claims for duties paid between 1 January 2021 and 30 June 2023 must be submitted by 30 June 2026—just over one month away. For duties incurred after 30 June 2023, traders have three years from the date of notification to claim.
The scheme applies to goods declared “at risk” of entering the EU. Traders can claim the full EU duty paid on movements from Great Britain to Northern Ireland, or the difference between EU and UK duty rates for imports from outside both territories. Evidence required includes sales invoices, export declarations, transport documents or proof of destruction, depending on where goods ultimately ended up.
Gaps and unanswered questions
The announcement leaves several operational details unclear. HMRC has not specified how the “interchangeable goods” flexibility will work in practice for complex manufacturing supply chains, nor has it quantified the expected reduction in administrative costs. The guidance on switching from CDWS to DRS remains pending, creating uncertainty for businesses that have already used waiver allowances.
Additionally, the changes come amid broader trade turbulence. The working group Dr Archibald established continues to assess the impact of US tariffs on Northern Ireland exporters, raising questions about how duty reimbursement interacts with new transatlantic trade barriers.
Questions for stakeholders
- How will HMRC measure whether the new “interchangeable goods” flexibility actually reduces administrative burdens for small and medium-sized enterprises?
- What support will be available for businesses that miss the 30 June 2026 deadline for backdated claims due to confusion about the new rules?
- Will the streamlined evidence requirements increase the risk of fraudulent claims, and how will HMRC balance facilitation with compliance?
- How do these DRS modifications interact with potential EU-US trade countermeasures currently being monitored by the Minister’s Tariff Working Group?
- Could linking the CDWS and DRS create unintended complications for businesses calculating de minimis aid allowances across both schemes?
What happens next
The success of these changes will depend on HMRC’s communication rollout and whether businesses can adapt before the June deadline. With the Windsor Framework’s democratic consent vote having passed in December 2024—albeit without cross-community support—the UK Government remains committed to smoothing trade flows within the UK internal market.
Traders should review their pending claims immediately, particularly for goods moved during the 2021-2023 period. Detailed guidance on the new processes is available via HMRC’s dedicated DRS portal. The Minister’s office has indicated that further engagement with business representatives will continue as the impact of these changes becomes clear.