HMRC has asked ICAEW to inform businesses that, from 15 December 2025, traders will no longer be able to use the current process in the customs declaration service (CDS) for handling indirect exports end-to-end from Northern Ireland (NI). 

The changes do not affect arrangements for moving goods directly from NI to Great Britain (GB), either under unfettered access or in the limited circumstances where declarations apply.

What is an indirect export?

For this purpose, the term “indirect export” refers to a movement of goods that:

• starts in NI; and
• departs the EU from a port of exit in an EU member state. 

A movement of goods that starts in NI and departs the EU from NI is not an indirect export. 

Alternative ways to move goods

HMRC says that businesses can continue to move goods by using one of the following alternative processes:

• Submit an export declaration in CDS. This remains an option where the business is moving goods through a port of exit in the Republic of Ireland (RoI). The business must ensure that:
  • DE 2/2 in the export declaration includes the additional information code ‘AG999’. The office of exit code the goods are intended to exit from in the RoI must be entered in DE 2/2 against code AG999.
  • DE 5/12 shows the office of exit as matching the office of export. HMRC says that, if the office of exit is entered as an EU location, it will be impossible to close the declaration.
  • The haulier carries a copy of the export declaration, either in paper or electronic format.
  • The movement reference number (MRN) of the declaration is included in the Irish Revenue’s pre-boarding notification for movements exiting on a roll-on, roll-off service. The MRN must be given to the airline or handling agent for movement exiting via air.
• Declare a direct export with the customs authority where the goods depart. This option is available where the goods are under €3,000 in value and are not subject to licence controls.
• Use the common transit procedure where the destination is within a common transit convention (CTC) country. GB is a signatory to the CTC. HMRC has published guidance on the common transit procedure and on moving goods to a CTC country.
• Make changes to the routing and move goods directly from NI. HMRC says that the majority of qualifying NI goods don’t require an export declaration when moved directly from NI to GB, unless this is required to fulfil an international obligation (for example, for the movement of endangered species). HMRC has published a step-by-step guide on exporting goods from the UK.
• Move goods under a single transport contract (STC). This is a contract with an airline or shipping company where that company takes over the carriage of the goods in NI. This option cannot be used for movements exiting by road, or goods subject to excise duty. Further information is provided in HMRC’s guidance.

Should the trader have any questions, HMRC can be contacted at AESteam@hmrc.gov.uk.