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Views on Europe | The Democracy Edition

Cenni Najy - foraus

Let’s go Swiss? Insights for British Eurosceptics

As an alternative to full EU membership, advocates for Brexit have taken Switzerland’s bilateral agreements with the EU as a model. In their view, it enjoys a large access to the EU internal market while preserving its own sovereignty. Moreover, some “Brexiters” have argued that an EU-exited UK would rapidly get a much better integration deal than the Swiss achieved.

The UK is indeed not comparable to Switzerland economically and demographically. Nevertheless, this does not mean much regarding the UK’s ability to strike a good exit deal. Swiss-EU relations give us some interesting insights for that matter.

Swiss-EU bilateral agreements and insights for Brexiters:

First, Switzerland’s attempts to secure internal market access was time-consuming as no institutional framework was in place to centralise negotiations. Furthermore, the bilateral agreements are, legally speaking, mixed agreements, requiring all EU member states to ratify them. The case of a UK withdrawal from the EU is institutionally different from what Switzerland faced. However, article 50 of the Treaty on the EU provides that any withdrawal agreement is to be negotiated in accordance to a lengthy procedure involving the remaining member states, the Commission and the Parliament. In addition, the withdrawal treaty of the UK will have to be concluded as a mixed agreement. Thus, it is difficult to imagine a quick new EU-UK settlement in case of Brexit.

Second, the idea according to which British negotiators “will have an easy task” to secure a close relationship with the EU due to the economic size of the UK is over-optimistic. Based on trade numbers, the EU is a critical partner for the UK, while the contrary is not true. Moreover, a withdrawn UK would barely be a more important trade partner to the EU[27 members] than Switzerland was when it negotiated its bilateral agreements (with a then smaller EU[12]).

Third, many EU member states might oppose the opening of ambitious bilateral exit negotiations with the UK. Indeed, any accommodating response would reinforce their own eurosceptic forces by showing that there might be a life after EU membership. Switzerland did not encounter this problem during its own negotiations with the EU as euroscepticism was only an emerging phenomenon in the 1990s.

Fourth, “sensitive” topics, such as free movement of persons, would in all likelihood feature on the negotiation agenda. Switzerland’s demands for a renegotiation of its own free movement agreement with the EU were firmly rejected.

Fifth, Switzerland in its bilateral negotiations continuously stressed that full EU accession was its “strategic goal”. Thus, from the EU’s perspective bilateralism was seen as a “provisional solution” before full accession. In case of Brexit to the contrary, the goal of the UK would be to leave without any immediate (re-)accession perspectives. The EU negotiators might therefore not have any incentive to accommodate UK demands in the same way as they did for Switzerland.

Swiss-EU actual bilateralism and insights for Brexiters:

Sixth, the EU states that for a third state to access parts of the internal market it has to follow most EU rules. This leads to the creation of a sovereignty deficit because countries like Norway or Switzerland have no real say on the EU legislation they implement back home.

Seventh, if one has a look at all bilateral agreements, it is true that Switzerland did get a large access to the internal market. However, some areas, such as financial regulations are not covered. Assuming the UK would get a deal close to the one Switzerland got, such “omissions” might be very problematic, especially for the British financial sector which operates in relation to Europe.

Eight, a report of the Swiss Federal Council (The federal government of Switzerland) found that maintaining the existing bilateral agreements, the participation in EU programmes/agencies and the financial solidarity contribution generated payments of up to 718 million Swiss Francs for the year 2013 (GBP 517 million). Any type of Swiss-integration would most probably cost the UK less than what it pays each year as a net financial contribution for EU membership. However, the bill might still reach several GBP billion.

In conclusion, from an outside perspective, it looks like Switzerland has nothing to do with the EU and only strikes deals where it sees an advantage. The reality is very different. Far from being a “holy grail”, Swiss bilateralism is in fact no model for any EU member state, including the UK. For the Swiss, the access to the internal market was difficult to achieve, despite the favourable environment in which it took place. Today, Swiss-EU bilateralism is marred with serious problems (sovereignty issues mainly) and is more and more costly. Therefore, Brexiters seeing Switzerland as a blueprint should think again…

Cenni Najy

Cenni is a teacher, researcher and political analyst. He is passionate about building Europe as a political and economic phenomenon. Since 2013, he leads a doctoral thesis on the Swiss-EU relations at the University of Geneva. Meanwhile, he holds the position of senior policy fellow (in charge of the Europe division) in the Swiss think-tank foraus.

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