As I
mentioned in my post on the British election result, one certain consequence of
it was that there will be a referendum as to whether the UK remains in the
European Union. This will have major consequences for Britain and for British
businesses but also for the EU itself and for those doing business with Britain,
and for those who currently come to live, work and study in Britain, and,
actually, for the way the world geo-politics are configured.
Already
there have been some important developments. First, who will get to vote in
this referendum? There are various possibilities but what seems to have emerged
is that the electorate will be those entitled to vote in a British general
election. One consequence of this is that it excludes 16 and 17 year olds,
unlike last year’s referendum on Scottish independence. Another is that
citizens of other EU countries living in the UK will not have vote unless they
have joint citizenship (there are some technical reasons why this does not apply
to Irish, Maltese and Cypriot citizens in the UK). A third is that British
citizens who have lived abroad for 15 or more years will not be able to vote.
This
decision on the franchise can be seen as an attempt to assuage the demands of
those who want Britain to leave the EU, in particular by excluding EU immigrants,
which looks like smart politics from British Prime Minister David Cameron, who
is widely believed to want the UK to stay in the EU. It heads off accusations
of a rigged vote. On the other hand, it seems entirely illogical. If Britons
who have lived in other EU countries for more than 15 years aren’t allowed to vote
(apparently on the grounds that they have substantively exited the UK for
another country) then why aren’t those from other EU countries who have lived
in the UK for more than 15 years (and so made a similarly substantive commitment
to the UK) not allowed to vote?
I know a
great many people in both camps and in fact two of my closest friends are a
French woman who has lived in the UK for 20 years, has a business, husband and
children here but can’t vote, and an Englishman who has lived in France for
almost 30 years but has children in the UK and pays taxes here but can’t vote. What
such examples really show is that the extent of European integration already
makes it absurd to try to separate out a British and non-British electorate.
The other
big development has been an indication that the question asked in the referendum
will be in the form (if not the exact words) of ‘should Britain remain a member
of the EU’. This is significant because it means that those arguing to stay in
will be arguing for a ‘yes’ vote, which is believed to be more psychologically
appealing than asking people to vote ‘no’. Thus, unlike the decision on franchise,
this seems to be likely to favour the pro-EU case (and hence has been
criticised by those who want Brexit).
Alongside
these really very important developments, the British Prime Minister has begun
the process of ‘re-negotiation’ with the EU. It is not really clear what this
means as there is no forum for such a re-negotiation and no mechanism for it.
Anti-Europeans perceive, rightly I think, that no fundamental re-negotiation is
possible, certainly not on the key issue of free movement of labour. The
question is whether something that looks like a substantive re-negotiation but
isn’t can be presented to the electorate as if it is. This is the hope of the
pro-EU group and the fear of the anti-EU group.
Yet this
attention to the terms on which Britain might stay in the EU completely fails
to address the equally, or even more, important question of the terms on which
Brexit might happen. Those advocating it oscillate between, and often treat as
interchangeable, quite different scenarios.
One is direct
single market access via European Economic Area (EEA) membership (the ‘Norway’
option). This is perfectly feasible, but wouldn’t deliver what Eurosceptics say
they want. Not in terms of sovereignty (Norway has less control than the UK
over the single market rules it must abide by), cost (Norway pays more per
head) or immigration (there is still free movement of people) or the ability to
negotiate third party free trade agreements (it does so via EFTA*).
A second
scenario is single market access via European Free Trade Area (EFTA) membership
by multiple bilateral agreements (the ‘Swiss’ option). That is much less
feasible, as Switzerland’s idiosyncratic position developed piecemeal over many
years. A Brexit on this model would have to negotiate multiple separate
agreements (Switzerland has 120) over an unknown timescale with no way of
knowing the outcome. The Swiss model does not enable free movement of services,
which would be a major problem for the UK’s service-based economy. Moreover,
the EU Commission is deeply hostile to the Swiss approach to free movement of
people, and it is simply inconceivable that an opt-out on free movement would
be granted alongside EFTA membership any more than it could be re-negotiated
within the framework of EU membership.
The third
scenario is a Free Trade Agreement (FTA) with the EU. It is absolutely crucial
to understand that this is not the
same as single market membership. In general, FTAs eliminate tariffs, whereas a
single market eliminates non-tariff barriers to trade and harmonises
regulation. A particular difference,
appealing to some Brexiters, is that an FTA would exempt the UK from free
movement of people. But the consequence would be that 2 million or more British
people working or living in the EU would lose their automatic right to live
there, so Brexiters need to explain what arrangements would be made for them
and for their families. It’s no good imagining that things would go on as at
present or that post-Brexit the EU is ‘bound’ to accept British immigrants on
rules other than those applying to other countries. Brexit (in this third
sense) won’t just be some sort of game, it will be a fundamental shift in which
Europeans lose their right to move freely to Britain and Britons lose their
right to move freely around Europe.
A UK FTA
with the EU would also mean ceasing to have access to the FTAs held between the
EU and other countries such as South Korea and Singapore – in due course the UK
might sign new deals, but that could not be guaranteed nor would the terms and
timeframe be known. What is certain is
that the UK on its own could never get a better FTA deal with such countries
than that which it enjoys via the EU, for obvious reasons of market scale.
The key
question would be whether the EU would sign such a deal, on what terms and in
what time frame. It cannot be assumed that a deal would be inevitable ‘because the
UK is a big economy’: plenty of bigger economies don’t have an FTA with the EU.
Anyway, it’s also the terms that matter: not all FTAs are the same. As regards time frames, the EU deals with
Singapore and South Korea took several years to negotiate: these kinds of
arrangements are incredibly complicated. What happens in the meantime?
Brexiters don’t say because they don’t know. They sometimes say that on exit it
will just be a matter of trading on WTO terms. But the WTO does not establish
global free trade, which is why individual countries negotiate FTAs within the
WTO framework. For example, under WTO ‘most favoured nation’ rules, on Brexit
the UK would pay a 15% tariff on food exports to the EU and a 10% tariff on car
exports. Of course trade would not completely cease on Brexit, but the issue is
on what volume and on what terms.
Even more
fantastical is the idea floated by some Brexiters of the UK joining a
Commonwealth free trade area. There is no such entity and no plans or
possibility to create one. This idea is simply nonsense.
It’s hard to
resist the conclusion that the anti-EU camp deliberately confuse the very clear
differences between these Brexit scenarios. When challenged that leaving the EU
will mean exiting the single market they invoke the Norwegian or Swiss model;
when arguing that leaving the EU means avoiding the free movement principle
they invoke the FTA model. This slippage really needs to be confronted and
challenged by what we now know will be the ‘yes’ campaign. And that campaign
needs to do something more than present the economic case for staying in: the
EU represents not just an economic bloc but also offers multiple opportunities
for study, research, culture and retirement. Moreover, it operates to secure
peace within Europe and is a force for projecting a European view into the
world polity.
It’s a
perfectly reasonable to say that we should leave the EU. But if the British people
are to be asked to vote for EU exit they deserve to be given a proper explanation
of what happens next. Just saying airily
that it can all be negotiated afterwards isn’t good enough, nor is it good
enough to conflate the very different options just outlined. And it will certainly
be no good saying afterwards that ‘we didn’t understand what we were voting for’,
the repeated complaint made by Eurosceptics about the 1975 Referendum. By then
it will be too late. There’s no way back in. Which is what makes it a big
moment.