After last Thursday’s historic vote to give up membership of the European Union, one thing is emerging very quickly: the so-called “EEA option” is fast becoming rather popular as an initial step out of the EU.

The key benefits of this EEA Option are:

  1. It is a Leave proposition i.e. the UK leaves the EU. It therefore answers the electorate’s instruction that was delivered on 23rd June to leave the EU . This is why people like me, who have spent over two decades campaigning to leave the EU, advocate it.
  2. It provides a safe harbour and a safe passage for the UK economy while a longer-term deal with the EU is worked out over several years. It is therefore a temporary transition option, not an end-goal, and therefore allows for a little more compromise in what the option has to offer. This is a very important point when considering the ultimate requirements of the British people.
  3. It helps keep Scotland in the United Kingdom by maintaining full single market engagement with the EU at the point of exiting EU membership.
  4. Any concerns about British Expats on the continent and existing EU nationals in Britain immediately recede, as does the position of Gibraltar in the Single Market, and the Northern Ireland question, pending a longer term deal.
  5. It is the one Leave proposition that looks closest to a ‘middle way’, thus acknowledging the fairly narrow margin of victory on 23rd June and the large pockets of support for Remain. It therefore has capacity to reunite the whole country after a very fractious and bruising campaign.

Now let’s cover what it actually is.

Firstly, “EEA” is short for the “European Economic Area”and this EEA model is one currently adopted by Iceland, Liechtenstein and Norway.

It involves participation in the Single Market but from a position outside EU membership. For reasons of terminology, one should note in passing that EU members are also members of the EEA but their EU membership means they are subject to the EU treaties, whereas Iceland, Liechtenstein and Norway are not. To be in the EEA, a country has to be in EFTA — the European Free Trade Association — and while there may be other ways to engage with the EU in an EEA-style way, let’s stick with the established EFTA route for now. Discussion of “EEA countries”, the “EEA model”, “EFTA/EEA” or even just “the EEA” therefore usually focuses on these three nations and this article is no different.

The EEA agreement was originally signed in 1992 and was constructed as a waiting room for those countries outside the EU who were candidates for eventual membership. Some of those candidates — Austria, Finland, Sweden — subsequently went ahead and joined the EU. But others did not, and the ‘waiting room’ function of the EEA has effectively now ceased as the remaining EEA countries have no intention of joining the EU. Switzerland, an EFTA member, never joined the EEA so has instead ended up with a complex web of bilateral agreements with the EU that took many years to agree.

The centripetal forces of the Eurozone and the opposing centrifugal forces of non-euro countries have played into the EEA no longer being a waiting room — forces that are also causing a rise in euroscepticism across the continent and prompting calls from some voices in the EU for a new type of associate membership.

The EEA model has thus become a state of existence attuned to the times and one that the EEA countries are very happy to maintain, despite a small number of their own leading politicians still wanting to join the EU. Indeed it has been noted that “the majority of Norwegian government and business literature is positive or balanced about the EEA agreement — it is hard to find anything clearly negative.” This may come as a surprise to the British voters, considering the Remain campaign’s use of some very pro-EU Norwegians to say how bad it is.

What are the EEA model’s key features? Without exploring the finer nuances (and there are some), here is a summary:

** indicates an indirect relationship via the EFTA Court for single market operation only

Other big benefits are that the option doesn’t require us to ‘unpack’ the whole UK/EU relationship in one fell swoop. In other words, confronting the logic of Leaver arguments that we are very deeply entangled with the EU in all sorts of areas. It is an enormous web of engagements and it would be foolhardy to try to do it all at once. A free trade deal is barely the half of it. Existing areas of cooperation or integration include:

  1. The EU and UK have a joint interest in managing airspace for civilian airliners
  2. We cooperate on maritime surveillance
  3. We jointly regulate radio and television frequencies and mobile telecoms generally to avoid conflict between services and to manage limited resources
  4. We have integrated approval systems for medicines, medical appliances, pesticides and hazardous chemicals
  5. We have also integrated systems for the approval of road vehicles and aircraft, and both road and aviation safety are areas for joint action
  6. Our consumer safety systems and approvals have been harmonised, so has food safety
  7. For better or worse, we are fully involved in the Galileo GPS programme, with a very heavy investment in the system — withdrawal from which would involve heavy losses
  8. We are also deeply embedded in the European Defence Agency, which is managing the Airbus A-400 project, on which we depend for our next generation of military transport aircraft
  9. We work together formally on monitoring the flow of illegal drugs into the region, and on drug addiction
  10. We cooperate on occupational health and safety systems, research and enforcement, and on improving work environments.
  11. We work together on weather (and climate) research and monitoring
  12. We have joint science programmes
  13. We have joint schools/university exchange programmes (which don’t actually require EU membership, as it happens)
  14. We are building a system of mutual recognition of professional qualifications — with a harmonisation programme in some specialities.

Another area of Leave argument that we have to confront is that the UK has spent 43 years outsourcing its world trade and deal-making capability to Brussels. That means the UK does not readily have the capability to absorb everything that the EU currently does on our behalf. We will need to build new capacity and competence in this area and the EEA ‘safe harbour’ buys that time.

One objection often raised regarding the EEA Option is around the Schengen zone and the fear of having to become a part of it. It is however a completely misplaced fear. Despite all three EEA countries also being in the Schengen zone, Schengen membership is completely separate to EEA membership. It is just that the three existing EEA countries have separately and individually chosen to be part of Schengen.

This begins to explain why one should start to consider an EEA option for Britain as a uniquely “British option”. Referring to it as the “Iceland Option” or the “Norway Option” always prompts people to wrongly focus attention on that particular country’s relationships with the EU, whereas no two countries are the same.

Britain will be different again. The EEA is merely the base model.

Other areas Britain can explore and promote when negotiating such a model with the rest of the EU are as follows:

  1. As well as the “emergency brake”, available for controlling EU/EEA immigration (that can be unilaterally pulled by Britain, just as it can be pulled by the other three EEA countries), there is the possibility of setting an upper limit on such migration — a quota. This starts to step closer to the “Australian style points system” much discussed in the referendum campaign. There is some precedent for this within the EEA.
  2. A parallel consultation should be launched on tougher domestic policies on immigration, and better enforcement of existing laws such as those covering gang masters, agency employment, multiple occupancy, and minimum living standards.
  3. Setting up a migration impact fund and increasing spending on Britain’s border resources.

Another possible hurdle is EFTA allowing the UK to join the organisation and the EEA agreement, and indeed the hurdle of EU members voting (or not) to allow the UK to join the EEA agreement as an EFTA nation.

So far there is every reason to believe EFTA countries would indeed welcome a large country like Britain, thereby instantly making EFTA the fourth largest trading bloc in the world. The question about the EU voting to allow Britain to shift to such a position is a complex legal area but would ultimately come down to a political grand bargain. It may however require Britain to pay more into EU coffers than one might ordinarily expect for an EEA country, but that comes back to the temporary nature of this option.

Finally, how can we be sure Britain won’t stay in the EEA ‘as constituted’? There are at least three answers to that:

  1. EFTA members are seeking some reforms to the EEA agreement as it is. Britain’s arrival to this position may be the catalyst for such change.
  2. The dynamics of Britain leaving the EU — potentially drawing Sweden, Denmark and others out to the same position — could also see a complete political realignment in Europe: of EEA, EFTA, and non-euro countries working together in a free trade association and acting as a counterweight to the highly integrated eurozone (which essentially becomes the new EU). And both groupings engaging in a Europe-wide single market with added checks and balances on migration.
  3. The UK can simply leave the EEA agreement in future. It isn’t a prison and it’s much less of a step to full independence from there than stepping away from the EU to full independence in one go.

There is thus plenty in this EEA/British Option that both Remain and Leave sides can agree upon, remembering of course that it is just one step in a bright new journey to become a Global nation once more.