BREXIT – The Truth Dawns

This might be the most important post about Brexit that you read this year. Please share it once you have read it. 

Disclaimer: In this post, we are going to exclusively talk about observable, verifiable facts. We will provide links.

Where something in this article is just our belief or opinion we will try to specify that clearly. If you see something incorrect contact us and we will be happy to change it.


This week, Theresa Mary May MP, the Prime Minister of the United Kingdom is due to make a speech in Florence

This speech is expected by many commentators to be a significant intervention in the Brexit process, with much speculation about the speech contents. 

BBC Political Editor Laura Kuenssberg has tweeted some comments about the speech:


Now it is worth bearing in mind that this is speculation, and we don’t know if it is reflective of the speech contents as they will be delivered.
But if accurate, the Prime Minister will be ruling out any existing ‘model’ for Brexit – i.e. she will not be seeking to replicate the relationship with the EU of Liechtenstein, Switzerland, Norway, Turkey, Iceland or even Canada.

Mrs May has expressed similar sentiments before:

“I’ve always said that we’re not looking to take a model off the shelf or a relationship that current exists because the UK is unique. We’re already in the European Union and so we have a relationship with the EU already. When we come out we want to make sure we negotiate a good deal, a bespoke deal, a deal that is right for the United Kingdom.”


As reported by the Guido Fawkes political news website, senior members of the Cabinet and civil servants are split over the form Brexit should take.

They report that Boris Johnson and Michael Gove want a ‘CETA/Canada plus’ model, but that Philip Hammond, Cabinet Secretary Jeremy Heywood and Olly Robbins, the DExEU permanent secretary; favour a ‘EEA minus/light’ deal.

If all the above is accurate, the Prime Minister is facing a few problems.

Firstly, she needs to quickly get her Ministers and MPs behind one vision. But let’s say she is able to do that and for argument’s sake it is the CETA+ approach – i.e. a free trade agreement (FTA) between the EU and UK, but with extra content around Services access, non-tariff barriers, the Northern Irish border and citizen’s rights.

The PM not only has to get her party to agree to it, she also has to get the EU to agree to it.

We believe that had the UK government planned out such a deal well in advance, held informal discussions with EU countries – and only then issued the Article 50 notification, it might just have been possible to get such a deal. 

However, time is rapidly running out – at midnight on 29 March 2019, the UK will leave the European Union. So a deal needs to be agreed and ratified by the European Council and Parliament (and potentially, national governments) by then. 

This would be challenging enough if the UK chose to follow an existing ‘off the peg’ approach – but by her own admission, the PM is not seeking an off the peg relationship with Europe. 

As she stated in her Lancaster House speech:

"We do not seek to adopt a model already enjoyed by other countries. We do not seek to hold on to bits of membership as we leave.

No, the United Kingdom is leaving the European Union. And my job is to get the right deal for Britain as we do."


So it has clear that Mrs May has consistently rejected any pre-existing models. Indeed, Robert Peston ITV’s Political Editor has stated in a recent post on Facebook about the speech that:

"It will be clear that Johnson has been out-manoeuvred, in that she will signal that the UK will in essence maintain its net budget contributions (of circa £10bn per annum) for at least two years after Brexit day, 30 March 2019 - to maintain current market access arrangements and reassure businesses they won't suddenly be hit by new tariffs and bothersome customs checks. She will reiterate how she wants to avoid the feared and loathed cliff edge for companies and citizens of tumbling out of the EU bereft of certainty about their tariffs, rights and obligations.
That said, it will also be evident that she has sidelined her chancellor, Philip Hammond, because her aspiration for after those two or perhaps three years of transition is for our future trading relationship to be what is known - in the ghastly jargon - as CETA plus, and not the Chancellor's beloved EEA minus.
What this means is we want a trade deal modelled on Canada's new one (CETA) with the EU, that has just become operative in interim mode, and not the more intimate integration with the EU of Norway or Switzerland.
The reason we are doing a Canada is there has been no resiling from the position taken by the PM in her landmark Lancaster House speech that Brexit means taking back control of immigration rules, lawmaking in general and the money we were hitherto obliged to pay into the EU budget - and such a reassertion of our sovereignty is incompatible with Norwegian or Swiss style access to the single market. Anyway all of that is broadly May's position, to be expressed tomorrow."



So that’s that then -the UK is going to pursue a special bespoke deal, based on the Canada model.
Except it isn’t that simple.

The EU’s chief negotiator Michel Barnier has previously said:

“Norway, Iceland and Liechtenstein have chosen to be part of the Single Market, to accept their rules, and who make a financial contribution to European cohesion. But I also think of Canada with who we’ve just negotiated a highly ambitious free trade agreement. Canada is not part of the Single Market and therefore has neither the opportunities nor the obligations. I’m sure everyone understands it will not be possible for a third country to combine simultaneously the benefits of the Norwegian model with the weak constraints of the Canadian model.”


Today in an official speech, Michel Barnier said:

"6 months have gone by since Theresa May's letter on 29 March 2017. 6 months will be necessary to allow for ratification before 29 March 2019.
There is therefore only one year left:
To swiftly reach an agreement on the United Kingdom's orderly withdrawal and to provide certainty where Brexit has created uncertainty: for citizens, for beneficiaries of EU programmes, for the new borders, particularly in Ireland.
To subsequently define the length and precise conditions of a short transition period, if the British government requests one.
To begin scoping our future relationship, in parallel to the finalisation of the withdrawal agreement. We will obviously continue to trade with the United Kingdom.
The future trade deal with the United Kingdom will be particular, as it will be less about building convergence, and more about controlling future divergence. This is key to establishing fair competition.
Naturally, if the United Kingdom wanted to go further than the type of free trade agreement we have just signed with Canada, there are other models on the table.
For example, Norway and Iceland have chosen to be in the Single Market, to accept the rules, and to contribute financially to cohesion policy.
But one thing is sure: it is not – and will not – be possible for a third country to have the same benefits as the Norwegian model but the limited obligations of the Canadian model.
And naturally, any agreement must respect the regulatory autonomy of the EU, as well as the integrity of its legal order.

Ladies and gentlemen, this new relationship will go well beyond a trade relationship and will also involve an external, security and defence dimension."


It couldn’t be clearer – he is saying we can’t have a free trade deal model that doesn’t involve freedom of movement and/or some sort of financial contribution (e.g. Canada) combined with full Single Market access (e.g. Norway). 

Reports on Politico have him saying:

“We are not going to mix up models...but each model is available.”


It seems to us that one of three things are likely – either:

  1. Mrs May knows all about this, but thinks it is a bluff and the EU will give the UK a bespoke deal in record time.
  2. Mrs May is so out of touch with the EU’s negotiating position that she doesn’t know what Michel Barnier has previously said. 
  3. She doesn’t believe she will be able to get a good deal and hopes to pin the blame on the EU somehow, by making an offer she knows they will refuse. 

It seems to us most likely that Mrs May is being advised by people who are telling her (for their own reasons) that the EU will capitulate, and even in the event of a ‘no deal’ the UK will thrive, so there is no need to worry about it. 

We at EFTA4UK are deeply worried about the future of the Brexit process, and advocate that the UK rejoins the European Free Trade Association (EFTA) and pursues a Iceland/Liechtenstein-style Brexit. 

This much-maligned option would allow the UK greater sovereignty than EU membership, subject to the lenient ‘hands-off’ EFTA court not the ECJ, would allow us to make our own trade deals around the world, would cost less and would allow us greater control over migration issues. As EFTA/EEA is ‘off the peg’ it would be possible to rejoin the EFTA when our EU membership ends, with no cliff edge. 

Every serious analysis and expert we have spoken to advocates this model for the UK – so why isn’t the government going down this route?

We can only speculate – and these are just speculations – but we theorize that certain people are pushing for a Hard Brexit in order to benefit financially  from a deregulated UK economy. While the country as a whole would likely suffer, they would clean up.

Who these people might be, we will leave for others to guess. But if you want a Brexit that is do-able in the time allocated, a Brexit that protects jobs and rights – you will sign the petition and join our campaign.  

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