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James Rothwell @JamesERothwell
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Over past year I've spoken to MPs, experts and ministers in Norway and Iceland about what they really think of EEA/Efta membership. So here's a monster thread on the pros and cons of what could end up as the UK's Brexit Plan B
For those new to this (hi!), these countries are in the European Economic Area (EEA) which gives them full access to EU's single market. Their judiciary works under the Efta court, instead of the European Court of Justice (ECJ). Hence "EEA/Efta".
In October I went to Oslo, where overall EEA/Efta was felt to be best compromise for a country that voted 52 per cent to stay out of EU and 48 per cent to join it.…
It was clear that while EEA/Efta was overall considered to be a big success, many feared they would eventually get "trapped" in a system that was inexorably drawing the country closer towards Brussels' regulatory orbit
On the big controversy - free movement - Norwegian experts had doubts that Article 112, the "emergency brake" on EU migration, could be triggered unless you could argue that immigration posed major threat to country. But others think it could work - see @SKinnock @NickBoles
Norway-style Brexit also means sending pro-rata payments to Brussels for single market access. But UK would be paying less than it does now - so arguably an end to "vast payments" as May puts it. Norway and Iceland view is that these payments are well worth it
In April, Iceland's foreign minister told me Brussels was starting to view his country's independence as a "nuisance." But, he added, EEA/Efta membership had overall been "tremendously successful."…
In March I went to the Norway-Sweden border, where it was clear that tech wouldn't be enough to allow frictionless trade, as Norway not in customs union. There were long queues at the main border crossing, though minor crossings were kept open.…
In May, Iceland's foreign minister told me that EEA/Efta had not prevented them from signing free trade deals. In fact, Iceland has an FTA with China. So Global Britain might not be dead (Caveat; only 300,000 people live in Iceland)…
Foreign minister also denied that Iceland had to adopt all EU rules without having a say in them. He said they only adopt 13 per cent of EU rules (estimates of this vary between 10 and 30 per cent depending on how you calculate it)
It's true that EEA/Efta countries can refuse to adopt an EU directive, but this comes at heavy cost of losing market access to the affected sector. Nether Iceland nor Norway has ever taken the plunge, though the latter came close over a postal directive.
FISHING. Iceland is not in the Common Fisheries Policy. Icelandic fisheries told me this was brilliant. But small fishing firms said they had been forced out of business by the Icelandic quota system, and warned UK not to do the same thing.…
Back in September, outgoing Efta court president Carl Baudenbacher said the Efta court was not subservient to ECJ. He pointed to fact that in certain cases, Efta had actually overruled the ECJ, citing a case on vitamin-fortified cereal.…
Baudenbacher also told me Efta would be delighted to have British judges on the bench. But I understand Norway, currently the big fish in the EEA/Efta pool, would be uncomfortable with this...
BTW at that time, there were reports that Baudenbacher had discussed UK joining Efta with Japanese officials who were very keen on a predictable Brexit. But when I put this to him he denied this was the case
In April, a German MEP told me that Norwegian MPs were lobbying EU to ensure that if UK did adopt EEA/Efta it would not get a superior deal. So if we do opt for Plan B there could be a fight on the horizon about UK getting preferential treatment.…
Overall, it appears that Norway-style Brexit is far more likely to win a majority in Parliament than May's deal. It's far from perfect but there are provisions included to satisfy both Remainers and Leavers - which is why Norway and Iceland are, ultimately, very happy with it.
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