Brexit, swiss "model", pros and cons in comparative perspective

• Main Authors: Schwok, René, Najy, Cenni Michelangelo
• Format: Book Part
• Language: English
• Published: Exiting the EU Committee, House of Commons (London) 2018
• Subjects: info:eu-repo/classification/ddc/320; European integration; European Union; European Union External Relations; Great Britain and the European Union; Brexit; Brexit UK; Norway; Pillar; Iceland
• Online Access: https://archive-ouverte.unige.ch/unige:110095

Contents 1-­ A summary of the main argument. 2-­ Two comparative tables of different (integration) regimes for third States. 3-­ A list of 12 common misconceptions on the Swiss-­EU agreement. 1-­ Summary Main argument : Swiss-­EU bilateral agreements are the worst form of EU agreement with (close) third countries, except for all the others.-­ This assertion is based on the assumption that the UK wants to maintain maximum access to the EU Single market, while preserving maximum formal sovereignty and independence. It is useful to adopt a comparative perspective to explain why the Swiss-­EU bilaterals compare well with other regimes (see also table 1 and 2 below): 1) The European Economic Area (EEA, also known as the " Norway model ") represents the best option for the UK to preserve its trade with the EU. Indeed, the EEA offers full access to the Single Market for EFTA states (Norway, Iceland and Liechtenstein). However, EEA membership would come with significant loss of sovereignty for the UK. EFTA countries are not part of EU institutions and have no decision-­making rights. EFTA experts are only consulted in early EU legislation phases. The EEA institutional framework is cumbersome and possesses supranational dimensions (EFTA surveillance authority and EFTA court-­ which closely follow the ECJ's case law). Besides, EEA membership comes with important financial obligations. EFTA countries are obliged to pay substantial amounts for the reduction of socio-­economic disparities in the EU. Last but not least, EEA-­EFTA States would have to accept UK's application to join the EEA/EFTA pillar unanimously. It appears that the Norwegian government has strong reservations on the matter. 2) The association agreements that the EU concluded with Ukraine (the " DCFTA " being the trade part of the agreement) have also been cited as a potential blueprint for the UK. The text of the DCFTA offers gradual access to the 1 Authors are grateful to Angus Wallace (GSI-­University of Geneva) for his editing support.