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Breaking Barriers: EU and UK Reach New Deal

Updated: Sep 13, 2023

By Winona Kamphausen

Brexit has been a long and complex process, with many difficult decisions. One of the most contentious issues has been Northern Ireland’s handling, which has a complicated history and is deeply intertwined with the Republic of Ireland and the United Kingdom. After Brexit, the EU and the United Kingdom settled the dispute over Northern Ireland. With the Windsor Framework, London and Brussels are getting closer again.

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The Brexit Northern Ireland Deal

Northern Ireland (NI) is a member of the United Kingdom but shares a border with the Republic of Ireland, making negotiations challenging due to the different customs unions. The Brexit Northern Ireland deal was negotiated to avoid jeopardising the Good Friday Agreement. This agreement de facto forbids a hard border on the Irish island ever again.

The Brexit Northern Ireland deal permits Northern Ireland to remain in the EU's Single Market while remaining within the UK’s customs union. It avoids establishing a hard border and ensures the free movement of goods between the countries within the Kingdom. However, recently, different customs procedures created heightened tensions, especially regarding trade between Northern Ireland and Ireland.

The Windsor Framework

On 27 February, UK Prime Minister Rishi Sunak and EU Commission President Ursula von der Leyen met in the hope of ending the Brexit Northern Ireland deal dispute. After long negotiations, this resulted in the Windsor Framework, which encompasses five main parts: VAT and alcohol, the Stormont brake, the removal of the Northern Ireland Bill, a section on pets, parcels and medicine, and the green/red lane solutions.

This last element is the most significant breakthrough. According to the original Northern Ireland Brexit deal, goods are checked in Northern Irish ports before entering the island, thereby creating a sea border.

The Windsor Framework now splits goods into two lanes. Goods heading for Northern Ireland are routed through the green lane, meaning they are not subject to inspection and require minimal paperwork. On the contrary, goods bound for Ireland and the EU enter the red lane and are subject to inspection. This new system reduces checks and paperwork for food products and also lifts the ban on specific products entering Northern Ireland.

In addition, VAT rules have been changed under the new agreement. Northern Ireland will be subject to the UK VAT system and exercise these rules on products ready for immediate consumption like beer or immovable items such as heat pumps. All other goods fall under the EU VAT system.

Another milestone is that now only three per cent of EU law is applied to Northern Ireland, giving back control to Northern Ireland and the UK. Furthermore, the deal introduces the ‘Stormont brake’, allowing the Northern Ireland Assembly to object to any new trade rules.

However, this can only be used for significantly different rules. For pet owners, it becomes easier to travel from the UK to Northern Ireland, by simply confirming that their animals are microchipped. Lastly, the Northern Ireland Bill, a controversial proposed legislation by former PM Boris Johnson which could have given the UK the power to scrap the old deal, has been withdrawn.

Reactions to the Milestone

In the UK, the ruling Conservative Party widely accepted the new agreement as well as the opposition. ‘Tory’ MP Steve Baker described his relief after the breakthrough and former PM Theresa May welcomed the deal because it “is in the best interest of all the people of Northern Ireland”.

Opposition to the Windsor Framework might only be expected by Brexit hardliners such as Boris Johnson. However, his potential rebellion is expected to “end up being small.” Overall, the deal was widely welcomed in the House of Commons.

Similarly, in the EU, the deal was seen as a success since, mainly due to the pressure of the EU, the Northern Ireland Bill was dropped. Von der Leyen welcomed the compromise by achieving “definitive solutions that work for people and businesses in Northern Ireland and that protect our Single Market.” Furthermore, she saw the deal as a turning point in the bilateral relationship, stating that it “mirrors one of close allies standing shoulder to shoulder in times of crisis.”

However, there might be opposition coming from the Northern Irish pro-Brexit Democratic Unionist Party (DUP). The DUP saw the Brexit Northern Ireland deal as a threat to their Britishness and opposed it so strongly that they refused to participate in Northern Ireland's power-sharing government unless their concerns were addressed.

Although a new deal has been reached, the DUP’s hesitation to sign the Windsor Framework might lead to the risk of a “political impasse” and a further strain on the Ireland-UK relationship.

The signals of improvement might not be enough for the Unionists. The DUP has announced that they will take their time to study the agreement but will likely not decide before April. Part leader Donaldson said that he wants to get the “right outcome for Northern Ireland rather than a rushed one.”

But, he also acknowledges that “in broad terms, it is clear that significant progress has been secured across a number of areas whilst also recognising [that] there remain key issues of concern.” While all parties agreed that the Windsor Framework is an improvement, whether the DUP will accept this remains to be seen.


The agreement between the European Union and the United Kingdom on implementing the Northern Ireland Protocol is a significant milestone in the long and complex Brexit process. The Windsor Framework has addressed some lingering difficulties with the Northern Ireland Brexit arrangement.

The most important breakthrough is the red and green lane option, the elimination of food-related checks and paperwork, and the lifting of bans on some products entering Northern Ireland. The new accord was broadly approved by the UK's ruling Tory party and was regarded as a victory by the EU.

However, it is still unsure whether all parties accept the Windsor Framework. Overall, the agreement is a positive step forward for the UK and the EU in the complex negotiations surrounding Brexit and Northern Ireland. UK Prime Minster Sunak claimed that it allows the UK to “take back control” while achieving a victory by having the Northern Ireland Bill dropped.

Both the UK and EU achieved their primary goal of helping to provide stability for NI., They showed that after Brexit, both sides are able to corporate and settle disputes through a compromise, opening the door to a closer and more constructive relationship in the future.

Sources: BBC, CNN, The Guardian, European Commission, Reuters, CNBC

Written by Winona Kamphausen

January 2023

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