HANOI UNIVERSITY

ENGLISH DEPARTMENT

GRADUATION THESIS

POST-BREXIT: POSSIBLE TRADE RELATIONSHIPS

BETWEEN THE UK AND EU:

WHAT IS THE BEST FOR THE UK’S TRADE?

Supervisor: HOANG QUY, M.A

Student: NGUYEN THANH LONG
Class: 10A14
Student code: 1407010129

Hanoi, May 20th 2018

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 HANOI UNIVERSITY
ENGLISH DEPARTMENT

GRADUATION THESIS

POST-BREXIT: POSSIBLE TRADE RELATIONSHIPS

BETWEEN THE UK AND EU:

WHAT IS THE BEST FOR THE UK’S TRADE?

Supervisor: HOANG QUY, M.A

Student: NGUYEN THANH LONG
Class: 10A14
Student code: 1407010129

I declare that this graduation thesis is original and has not been submitted
for assessment elsewhere.

Hanoi, May 20th 2018

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 ACKNOWLEDGEMENT

First and foremost, I would like to express my sincerest gratitude to my supervisor, Mrs.
Hoang Quy, lecturer of English Department, Hanoi University, who expertly and
thoroughly guided me all the way to the accomplishment of my graduation thesis. Her
enthusiasm and valuable suggestions kept me constantly engaged with my research and it
never crossed my mind that I could be able to complete my dissertation without her
support.

My appreciation also extends to all the teachers of English Department, Hanoi University,
for giving me this precious opportunity to write this thesis as well as their encouragement
and orientation which made up for a major part of the fulfilment of my research paper.

We would like to spread our sincere thankfulness to all of the member of class 10A14 for
their generous assistance. We deeply appreciate their constant encouragement and
immense.

Last but not least, I am also indebted to my beloved family and friends who always love
and support me unconditionally and constantly from the very first stage of getting ready
to the completion of this thesis.

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 ABSTRACT

In 23rd June 2016, A in-or-out referendum was conducted nationwide in the UK to

answer a question whether the United Kingdom should leave the European Union or not. .
The outcome was shock, however, reflect the people’s will to take a departure from the
EU. Since the UK was a member of EU, it received full trade advancement from the EU.
However, when British decided to leave, a new trade relationship between the UK and the
EU has to be established. The choice is not easy to choose since there are pros and cons in
each possible relationships. Therefore, a period of 2 years has been set for both the UK
and the EU to negotiate the relationship. What possible trade arrangements could be
established? The work would make a clear analysis on the probable trade relationships.

Key words: Brexit, the UK, the UK, WTO, FTA, Customs Union, EFTA.

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 TABLE OF CONTENTS

CHAPTER I. INTRODUCTION

1.1. Background to the study

1.2. Aims of the study

1.3. Scope of the study

1.4. Organization of the study

1.5. Research questions

CHAPTER II. LITERATURE REVIEW

2.1 What is Brexit

2.1.1. Definition of Brexit

2.1.2. History of the idea of leaving the EU

2.1.2.1. The first referendum

2.1.2.2. Unaccomplished referendum commitments

2.1.2.3. Tensions between the UK and the EU in 1990s and 2000s

2.1.3. Referendum of 2016

2.1.3.1 Cameron’s guarantee and pre-negotiation of the referendum.

2.1.3.2. The result of Brexit referendum

2.2. Negotiation process on the UK's Post-Brexit Arrangements

2.2.1. The new government

2.2.2. The Brexit negotiation

2.3. Possible trade relationships between the UK and the EU

2.3.1. World Trade Organization (WTO) option

2.3.2. Free Trade Agreement (FTA) option

2.3.3. Custom Unions Access option

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 2.2.3. European Free Trade Association (EFTA) option

CHAPTER III. METHODOLODY

3.1. Subjects of the study

3.2. Research instruments

3.3. Procedure

CHAPTER IV. FINDINGS AND DISCUSSIONS

4.1. World Trade Organization (WTO) option

4.2. Free Trade Agreement (FTA) option

4.3. Custom Unions Access option

4.4. European Free Trade Association (EFTA) option

4.4. Comparison between options

CHAPTER V. CONCLUSION

REFERENCES

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 CHAPTER I. INTRODUCTION

1.1. Background to the study

After having described the steps foreseen by the Article 50 TEU, and seen the
positions of the UK governmernts and EU leaders. This work analyze the possibile
outcome of the negotiations. Theresa May said “Brexit means Brexit“. The UK
Government pictured a situation where the UK remain linked with the EU by a kind of
agreement, which will keep it as close as possible to the EU. Advises would be suggested
in the paper.

1.2. Aims of the study

The reseach attempts at investigating possible trade relationship between the UK

and EU via collecting and analyzing datas on available relationships between the EU and
other nations to discover the most suitable trade arrangement for the UK. An objective
view of Brexit and possible trade relationships between the UK and the EU which are
mentioned in prior research by scientists and scholars in the world is also presented for
better understanding of the issue.

1.3. Scope of the study

Since trade relationships exist between nations or groups of nations in the world,
the research mainly focuses on available trade arrangement between the EU and others
countries to determine the best one for Britain. This paper is expected to give readers an
insight into the issue of trade relationship based on which they can shape their perception
towards the advantages and disadvantages in certain situations.

1.4. Structure of the study

The thesis consists of 4 chapters.

Chapter 1 aims at introducing background, aims, scale and organization of the

study.

Chapter 2 provides readers a review of literature and relevant theories associated

with the topic of the thesis. Firstly it illustrates background knowledge about the

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definition, history of Brexit as well as the UK’s situation before and after the 2016
referendum. Thereafter, it presents readers with a number of possible trade relationships
with the EU which the UK could make a decision.

Chapter 3 is regarded as the main part of the thesis. It indicates the findings of the
research and answers research questions of what possible trade arrangements between the
EU and the EU could be decided and what relationship would be the most suitable. A
specific comparison between relationships is going to be revealed and analyzed in this
chapter.

Lastly, chapter 4 summarizes the ideas presented in the study as well as offers some
suggestions for further study.

1.5. Research questions

With the aforementioned aims, this research will be seeking for answers to these
two following questions:

- What happens to the UK’s trade when choosing each relationship option with the EU?

- What is the best option for the UK’s trade?

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 CHAPTER II. LITERATURE REVIEW

2.1. What is Brexit?

2.1.1. Definition of Brexit

The term “Brexit” is the result of lexical phenomenon adopted as a shorten path of the
idea of the United Kingdom (UK) leaving the European Union (EU) by combining two
words “British” and “exit” to establish a fresh new word, Brexit (Hunt & Wheeler, 2018).
The term were inspired from the situation of Greek potential leaving from the EU which
was named Grexit, merging the words “Greek” and “exit” (Moseley, 2016).

Brexit refers to the potential departure of the UK from the EU before the Referendum in
June 2016 to decide if the UK leave the EU or not. The word “Brexit” was first used by
people who wish on the leaving EU of the UK then widely mentioned by others (Hunt &
Wheeler, 2018). After the Referendum, the majority of British voted to leave. Brexit had
become successful and the British Government started to withdraw the UK out of the EU.
At the moment, the UK Authorities are negotiating on terms of the nation after the
referendum and it is set that 2019 will the year of official departure (Walker, 2018).

Peter Wilding, the founder and director of the British Influence, was discovered as the
first recorded person to use the word “Brexit” by The Oxford English Dictionary. Mr.
Wilding, who supports the idea of remaining in the EU in 2016 referendum, gave a tweet
including the coinage "Brexit" in May 2012, more than a half of a year before a
referendum was officially revealed to be held in the future by the resigned Prime Minister
David Cameron (Moseley, 2016). The term “Brexit” was chosen to be the 2016 most
important English title by lexicographers at dictionary publisher Collins. It was
researched that usage of the expression for the UK’s abandon from the EU has received a
rocketed surge at the rate of above 3,400% in the year of 2016 (Cooper, 2016).

2.1.2. History of the idea of leaving the EU

2.1.2.1. The first referendum

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It was not until recently that the idea of leaving European Union became remarkably
striking. The story behind has been led back to the post-period of World War II.
In 1951, the "Inner Six" including France, West Germany, Italy, Belgium, the Netherlands
and Luxembourg signed Treaties of Paris to form the European Coal and Steel
Community (ECSC) (Alter & Steinberg, 2007) soon after, the European Economic
Community (EEC) and the European Atomic Energy Community (Euratom) were
established as a result of Treaty of Rome (Sarah Pruitt, 2017). In 1967, Mergers Treaty
came into effect to merge the three communities to be commonly recognizable as the
European Community (EC), the predecessor of the European Union (Huet, 2014). The
UK was seeking approval on British membership in the EEC in 1963 and 1967 during
Harold Macmillan and Harold Wilson’s term of office respectively, however, both
attempts were vetoed by the contemporary French president, Charles de Gaulle (Tickell,
2016). After his presidential relinquishment, the 1972 Treaty of Accession signed by the
Conservative Prime Minister Edward Heath to the ECC officially apprehended the UK
enrolment on 1 January 1973 (Sorokina, 2014). However, the verge of backing out arose
roughly two years later.

The Labour Party engaged the 1974 election with a promise to advance Britain's
membership in European Community as well as organize a referendum whether to remain
to the ECC. After Labour's victory, the United Kingdom's first national referendum on the
question: “Do you think the UK should stay in the European Community?” was
conducted in 1975 The referendum was held on 5 June 1975 and the result revealed
that 17 378 581 British electors chose “Yes” and 8 470 073 said “no”. The overwhelming
majority of 67.2 % citizen on the side of the UK remaining in the EC hit Eurosceptics in
Britain with a shocking reality (Meyer, 2016). However, Britain’s role in Europe was
surrounded with controversy.

2.1.2.2. Unaccomplished referendum commitments

Relationship between the UK and the EEC faced a negative impact in 1984 since the
Labour Party engaged in the 1983 general election with a withdrawal promise from the
EEC (Clark, 2008). The victory of Conservative Government of Margaret Thatcher

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defended the bilateral connection. However, significant attention about the EU appeared
during the Iron Lady’s term leading to the discussion on declining Britain’s contribution.
From more than 20% in the ‘80s to about 12% was the idea of negotiation on reducing
Britain’s payment to the EU budget (Negadi, 2017).

Another referendum commitment was announced in 1994 when the Referendum Party
established by Sir James Goldsmith, with the clear ambition to hold another referendum
on the EU membership of the UK (Rentoul, 1995). In addition, the Harold Wilson’s
Labour Party made a guarantee of renegotiating the UK’s received membership and a
referendum on whether to stay in the EU with the new agreements was committed to
organize if the election campaign received successful result (Miller, 2015)

2.1.2.3. Tensions between the UK and the EU in 1990s and 2000s

Under the term of the Maastricht Treaty, the EEC became the European Union (EU) in
1993. Gradual integration on European nations on politic and economy, including a united
foreign obligation, collective citizenship rights and a unique currency, the Euro was an
important term of the treaty (Bindi, 2010). The UK’s strong reaction against the creation
of the Euro led to the result of denial of the Euro and the Pound are remaining in use
nowadays. This formulated another considerable difference between EU members and the
UK (Sorokina, 2014). The UK in the late 90s faced the crisis of the “mad cow”. A ban on
British beef has been imposed by the EU and only lifted in 1999. In 2000, after a 27-year-
long of struggling, British chocolate reached a permission to be sold in the rest of Europe.
In France, Belgium, Spain and Italy, among other countries, had claimed British chocolate
only cocoa butter British-made chocolate–including popular brands like Mars Bars, Kit-
Kats and Cadbury’s was believed to contain significant high amount of milk, and sought
for labels such as “household milk chocolate,” “chocolate substitute” or even “vegelate.”
(Salmaso, 2016).

In 2007, the Lisbon Treaty was successfully negotiated which generated stronger powers
for the EU. One of the central pillars of the EU is the freedom of movement and residence
of persons in the EU which was enforced by the Treaty of Maastricht in 1992 for the idea
of the European Citizenship. The Lisbon Treaty reconfirmed this term (Brunazzo &
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Settembri, 2010). Anger and disappointment has emerged inside the UK since these
treaties has considerably limited its sovereignty and demand for a referendum was surged.

Tensions between the UK and EU had been filled up with those matters from 1990s to the
2000s. This led to a worsen relationship between the nation and the organization. For this
reason, the United Kingdom Independent Party (UKIP) was established to represent a
group of Eurosceptic people. The party had been playing as protesters to the UK’s
membership of EU since then (Whitaker & Lynch, 2011). After the UK parliamentary
expenses scandal in 2009, UKIP witnessed an immediate surge in support and put
pressure on the Government for an in-or-out referendum (Salmaso, 2016).

2.1.3. Referendum of 2016

2.1.3.1. Cameron’s guarantee and the pre-negotiation of the referendum

At the 2010 general election, the Conservatives won a majority of seats in the House of
Commons. During the campaign on the election, "cast iron" commitment of a referendum
on the Lisbon Treaty was made by the Conservative party leader, David Cameron.
However, it never happened due to the EU’s intervention. In January 2013, another
commitment to negotiate more favorable policies for British membership of the EU
before holding a referendum on whether the UK should remain in or leave the EU was
composed if the Conservative Party reach the 2015 general election victory. A draft EU
Referendum Bill issued in May 2013 contains a plan for renegotiation followed by an in-
out vote

When the general election of 2015 was successfully apprehended by the Conservative
Party led by Cameron who received more favorable votes, a reiteration on his manifesto
assurance on an in-or-out referendum on UK membership of the EU by the end of 2017;
however, “negotiating a new settlement for Britain in the EU” must be settled before the
vote (Salmaso, 2016).

In early 2014, changes in relationship between the UK and the EU were handled by the
Prime Minister in indication for his objectives. These were additional immigration
controls, especially for citizens of new EU member states; tougher immigration rules for

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present EU citizens; new free-trade agreements. The Conservative leader intended to
handle these proposals during the process of negotiations with other EU leaders and if re-
election happened, a referendum would be announced (Negadi, 2017).

In November of the same year, a crucial apprise on the negotiations and further terms of
intention was released. “The key demands made of the EU were: on economic
governance, to recognize officially that Eurozone laws would not necessarily apply to
non-Eurozone EU members and the latter would not have to bail out troubled Eurozone
economies; on competitiveness, to expand the single market and to set a target for the
reduction of bureaucracy for businesses; on sovereignty, for the UK to be legally
exempted from “ever closer union” and for national parliaments to be able collectively to
veto proposed EU laws; and, on immigration, for EU citizens going to the UK for work to
be unable to claim social housing or in-work benefits until they had worked there for four
years, and for them to be unable to send child benefit payments overseas” (Salmaso,
2016, p.53).

The outcome of the renegotiations was announced in February 2016. There was to be no
fundamental change to the EU–UK relationship were agreed. The failure in parleying led
to a disadvantage for Cameron’s government in the wish to stay in the EU.

2.1.3.2. The result of Brexit referendum

In February 2016, Cameron announced that the UK Government would formally that the
referendum would be held on 23rd June, marking the official launch of the campaign. To
enable the referendum to take place, the European Union Referendum Act was passed by
the Parliament of the United Kingdom. It extended to include and take legislative effect
(Julie Smith, 2016)

The referendum was conducted in the UK on Thursday, 23rd June. On the day after,
Friday 24th June 2016, the final result of the referendum was formally announced. UK
population voted to leave the European Union. The majority of 51.9 % over the 72% of
the eligible voters backed the exit. The difference was not distinct yet enough to give a
clear outcome of the referendum. Over 33 million people voted, with 17 million backing

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Leave (51.9 per cent) compared to 16 million voting to Remain (48.1 per cent). The
Leave campaign then won by just 3.8%. (Deloy, 2016)

2.2. Negotiating process on the UK's Post-Brexit Arrangements

2.2.1. The new government

“The lack of leadership in the UK ended at the beginning of July when Conservative
leadership election was triggered as Theresa May won the election to be become leader of
the Conservative Party” (Salmaso, 2016). On 13th July 2016, The Queen officially
appointed her as Prime Minister of the UK. Despite Theresa May’s support on Cameron’s
idea of remaining in the EU on the Brexit referendum, she received the responsibility for
implementing the nation's withdrawal then. The madam PM revealed commitment to
conduct Brexit, as testified by the famous declaration “Brexit means Brexit” eventually
presented herself as Prime Minister on the mass media (Salmaso, 2016)

In her new government, Mrs May named in keys positions ‘Brexit’ supporters. However,
her Government includes more ‘Remainders than Leavers. In fact, there are 16 cabinet
members, including Mrs. May, who backed Remain, and seven who campaigned for
Brexit. The “European Union Exit and Trade Committee” is formed by the four Leavers,
together with Transport Secretary Chris Grayling and Environment Secretary Andrea
Leadsom also prominent members of the Leave campaign. (Salmaso, 2016).

The new Prime Minister is using all of her effort to handle a difficult situation and she
probably understands that the negotiations with the EU are going to long exhausting. Mrs.
May pushed the for-Brexiters to the forefront, trying to propose the idea of Brexit is
difficult to handle and she might want the best people for the job. The aim is gaining
possibility of suitable option for Brexit to and prove on the economical independency of
the UK from the EU.

2.2.2. The Brexit negotiations

“The Brexit negotiations are taking place between the United Kingdom and the European
Union for the prospective withdrawal of the United Kingdom from the European Union,
following the UK's referendum on EU membership in June 2016” (Salmaso, 2016, p.54).
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A negotiating phase started on 29 March 2017 as the United Kingdom triggered the
withdrawal under Article 50 of the Treaty on European Union. Two years from
notification will be the duration of the stage for negotiation stated in Article 50 unless an
extension is agreed (Soares, 2017). On 19 June 2017, British Secretary of State for
Exiting the European Union, David Davis, arrived in Brussels to negotiate Brexit terms
with European Chief Negotiator for the United Kingdom Exiting the European Union,
Michel Barnier. The withdrawal agreement, a temporary transitional period agreement,
another agreement for the post transitional period and the most important, trade agreement
treaties between European Union and the UK would be deliberated during Brexit
negotiations (Lang & Miller, 2017) Therefore, a new kind relationship between the EU
and the UK would be formulated in the end of negotiation period. Mrs. May outlined UK
wants to keep control immigration and be free to pass own laws and dictated her
condition for the agreement, which should reflect a free trade deal, in goods, services and
capitals. “This is going to be a deal that works for Britain”, she informed (Salmaso, 2016,
p.129).

2.3. Possible trade relationships between the UK and the EU

2.3.1. World Trade Organization (WTO) option

The World Trade Organization (WTO) was born on 1st January 1995, but its trading
system had been settled since 1948, the General Agreement on Tariffs and Trade (GATT),
which had delivered the rules for the system. Arcording the the House of Lord of the UK,
“As a global framework for trade relations between countries, it aims to liberalize trade by
lowering tariffs and reducing or eliminating other barriers to trade (thereby improving
market access), and to create a stable and predictable trading system. Tariff reductions
and increasingly the reduction of non-tariff barriers are negotiated between WTO
members” (Lang & Miller, 2017, p.21) . The WTO currently consists of 164 nations
which makes up for 95% of world trade. In order to create a predictable trading system,
the WTO applies nondiscrimination principles.

One of the WTO principles is “most favoured nation” (MFN) treatment, which requires
countries “cannot normally discriminate between their trading partners. This includes the
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obligation to apply the same tariffs and to offer the same market access to all WTO
members” (“Brexit: Option for trade,” 2017, p.51). If a country decides to decrease a
trade barrier or to open up its market for one WTO member, the same favorable
conditions must be imposed to all WTO trading partners. The MFN principle applies to
trade in both goods and services (“Understanding the WTO,” 1995). According to House
of Lords, exceptions are possible, either if countries set up a free trade agreement (FTA)
or customs union, or if a special trade conditions to developing countries are given. In
services, countries are allowed to discriminate in additional limited circumstances. MFN
includes the principle of ‘national treatment’, which give a good or service once imported
into a market a treatment like a local product. WTO membership contains a balance of
negotiated ‘rights’ and ‘obligations’

After the trigger of the Article 50 TEU, 2 years are needed to negotiate the terms of the
exit. If no agreement will be reached, the UK will be automatically pulled out the EU.
This leads to a problem that a requirement on trade within the framework of the Word
Trade Organization would be executed on the UK. However, the WTO option is by no
means guaranteed. The WTO members are 162 countries and not all of them will be
interested to negotiate immediately and on the basis of the previous tariffs of the EU to
the UK. (Hoekman et al, 2017)

2.3.2. Free Trade Agreement (FTA) option

The model of a Free Trade Agreement between the UK and the EU will generate a closer
integration within the continent, avoiding the comeback to the WTO tariffs. The British
economy (the fifth largest in the world) and its importance to the rest of the EU (the
source of 53% of British imports) would ensure that the UK could obtain an FTA on very
good terms (Winders, 2016).

Indeed, the proposed relationship has conducted interest to the US and China while
concrete requests have been handled by New Zealand and Australia. However, the term
‘free trade agreement’ is misleading. Most FTAs do not provide for free trade, but rather
for better market access than that provided by WTO rules, also FTAs usually say very
little about trade in services” (Salmaso, 2016, p.154). Recent FTAs negotiation of the EU,
14
such as those with Canada and Singapore, has reached the harmonization of norms and
standards (Salmaso, 2016).

The only really comprehensive FTA would be the Transatlantic Trade and Investment
Partnership (TTIP), currently under negotiation between the EU and the US, but
possibility of abortion appears due to the change of Governments both in the EU, the US
and the UK itself. Currently the Comprehensive Economic and Trade Agreement between
EU and Canada (CETA) is only real comprehensive Free Trade Agreement finalized by
the EU and it would be the model for further similar agreements. Moreover the UK has
been negotiated with the EU, being also the main Canada commercial partner, so it is a
model can be approved (Khorana, 2015).

For this option, the UK would have no obligations associated with integration into the
Single Market. However, that would mean a dramatic increase in the barriers to access
to the EU, as UK exporters to the EU would still be required to prove they meet
EU regulatory standards on products they wanted to export to the EU. Market access
rights for some services sectors would be severely restricted. (Owen et a, 207)

2.3.3. Custom Union Access option

“The European Union Customs Union, consisting of all the member states of the EU and
a number of surrounding countries (i.e. EFTA countries – Norway, Iceland, Liechtenstein
and Switzerland), is a group of economies with no internal barriers to trade and a common
external tariff” (Kesner-Škreb, 2010, p.2). The Customs Union is a central part of the EU
which allows member nations trade freely with each other and charge the same agreed
tariff on imports from outside of the EU. The same tariff on countries importing goods
into the EU need to be paid regardless of which countries goods are imported to.
Fundamentally, the Customs Union members are not allowed to negotiate their own trade
deals in other places in the world as the tariff arrangements of the EU are executed. The
Customs Union is an essential element in the functioning of the single market and fulfils a
principal task of the European Economic Community established in 1958 by the Treaty of
Rome. The single market can only function properly when there is a common application
of common rules at its external borders. No customs are levied on goods travelling within
15
the Customs Union and members of the Customs Union impose a common external tariff
on all goods entering the union. (Kesner-Škreb, 2010)

Customs Union is the one in place between Turkey and the EU since 1995. A Customs
Union eliminates internal tariffs and requires the participating countries to agree on
common external tariff. Thanks to this, Turkey can have access to the European Single
Market. The Customs Union covers all industrial goods but does not address agriculture,
services or public procurements. In addition, a Custom Union provides a common
external tariff for the products covered. Turkey will not have access to US or Canada
countries markets (Karatas, 2016) This can be seen however as an advantage, leaving the
UK free to establish its own agreements. Regarding the free movement of people, no
provision is settled. The Turkish model would provide only limited access to the EU’s
internal market, yet would deprive the UK of sovereignty on trade policy.

According to House of Lord of European Committee, a key aspect of Brexit will be the
feasibility of the UK remaining part of the customs union: the Government will need to
decide early on whether or not the UK should do so. Although Turkey offers an example
of a country outside the EU having a customs union with the EU, its participation is
fundamentally different from the UK’s participation as a full EU Member State. We are
concerned that the Government appears not yet to have given sufficient consideration to
the implications of leaving the EU’s customs union (2017).

2.3.4. European Free Trade Association (EFTA) option

European Free Trade Association, or EFTA, is an intergovernmental organization set up

for the promotion of free trade and economic integration, currently formed by four
nations: Iceland, Liechtenstein, Norway and Swiss. On 4 January 1960, Austria,
Denmark, Norway, Portugal, Sweden, Swiss and the United Kingdom signed in
Stockholm a Convention to establish the EFTA. The association was joined by Finland in
1986, Iceland in 1970 and Liechtenstein in 1991; while losing Denmark and United
Kingdom in 1973, Portugal in 1986, Austria, Finland and Sweden in 1995. All of these
countries joined at the same time the EEC

16
The important aspects of modern trade, including provisions on the free movement of
persons, trade in services, movement of capital and protection of intellectual property is
covered in EFTA. It has led to a strengthening of economic relations between the EFTA
Member States and also provides an enhanced common platform for developing relations
with trade partners around the world (Maurer, 2016). EFTA today maintains the
management of the European Economic Association (EEA) Agreement (EFTA-EU
relations). The EFTA Convention effectively applies to relations between Switzerland
and the EEA EFTA members, as trade relations between Iceland, Liechtenstein and
Norway are largely governed by the EEA Agreement. It is updated regularly by the EFTA
Council to reflect common developments under the EEA Agreement and the Swiss
bilateral agreements with the European Union (EU), ensuring that the EFTA States
benefit from virtually the same privileged relationship among themselves as they do with
the EU (Bagnall, 2013).

EFTA membership could be a beneficial option for UK-EU trade, not least because it
would maintain trading with EU members and EFTA nations as well. It would also
provide partial membership for the UK to trade within the EU with limited advantages.
However, joining the EFTA means the UK would have to accept a numbers of regulations
from the EU which British Government would want to avoid and this may lead to failure
of negotiation. (Owen et al, 2017).

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 CHAPTER III. METHODOLOGY

3.1. Subjects of the study

The subjects of this research are a number of possible trade relationships between
the UK and the EU. A comprehensive comparison is designed to investigate possible
trade relationships between the UK and EU via collecting datas on available relationships
between the EU and other nations. Criteria to be analyzed are the movement of goods,
services, people, trading ability with EU members and contribution to the EU budget.

3.2. Research instruments

This research applies two research instruments in order to gather and analyze the
data which is written information.

Written information has been gather to understand perceptions, beliefs or

experience of various researchers and scientists. Due to the development and widespread
use of the Internet, secondary information is convenient for researchers as they can save
time and money to cite previous information which has been determined.

Another research instrument is listing which is used to represent the data collected
for further analysis and explanation. From gathered secondary information, each would be
located in suitable parts for readers to comprehensively understand the problems.

The last instrument is table for comparison. Table is a suitable method to make a
comparison among each possible trade scenarios to discover advantages and
disadvantages. Therefore, the most suitable one would be revealed.

3.3. Procedure

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 In order to investigate the issue of possible trade relationships between the UK and
the EU, a list of potential relationships and a comparison of information were developed.
The list are presented in to scrutinize the information on the probable trade arrangements.
Each trade arrangement would be analyzed in five criteria which are the movement of
goods, services, people, trading ability with EU members and contribution to the EU
budget. What happens to the UK trade in five criteria would be carefully examined.

After listing investigated potential trade relationships between the UK and the EU,
tables for comparison has been established. Five tables represents five criteria which are
the movement of goods, services, people, trading ability with EU members and
contribution to the EU budget has been set. In each table, the characteristics of each trade
arrangements are evaluated. Ultimately, the option containing more favorable terms
would be chosen to be the most suitable one.

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 CHAPTER IV. FINDINGS AND DISCUSSIONS

After the choice of British citizens to leave the EU, the new Prime Minister Theresa May
wants to replace the loss caused by the end of the EU membership with a possibility for
new trade deals. However, EU access to the Single Market as imperative for the British
economy. The ultimate aim of negotiation period is collecting full access to the Single
Market, which is a place of free movements of goods, services among the EU members,
without making any contributions and allowing immigration from the EU. However, this
scenarios is seemed to be unreachable. Therefore, a new trade relationship must be
negotiated.

This chapter attempts in analyzing retrieved the data in order to figure out the answers
for the research questions mentioned before about the UK’s trade when choosing each
relationship option with the EU. Furthermore, specific comparison among five standards
which are movements of goods, services, people, trading ability with EU members and
contribution the EU budget is going to be conducted and discuss thoroughly so that the
most suitable trade relation could be indicated.

4.1. World Trade Organization (WTO) option

The default option would be a hard Brexit with no agreement between the UK and EU. In
this case, the UK’s trade arrangements with the EU would fall back on to the WTO
standard, the so-called “most-favoured-nation” (MFN) tariff. The relevant tariffs would
be the current EU tariffs bound in the WTO. In principles, the UK would be able to
charge lower tariffs on imports from the EU and elsewhere, for example to limit the
inflationary effect on consumers. However, the UK might prefer to retain the existing

20
tariffs as a bargaining chip in negotiating trade deals with non-EU countries. EU tariffs
are mostly very low though significant in some areas (Hine, 2017).

The basic alternative to being a part of the Single Market is to be outside of the single
market but trading with it. This is the status of most countries in the world and is often
referred to in EU law and practice as being a ‘third country’. Third countries can access
the single market in many ways. Some of this access is guaranteed and protected by
World Trade Organization (WTO) rules or bilateral agreements signed with the EU.
(“Implications of the leaving the EU single market,” 2017)

Movements of goods

Suppose the UK leaves the EU without putting in place any of the alternative
arrangements discussed above. Then the country’s trade with both the EU and almost all
the rest of the world would be governed by the WTO. There are, however, WTO rules on
tariffs which govern how they are applied. The principle of non-discrimination requires
WTO members not to treat any member less advantageously than any other: grant one
country preferential treatment, and the same must be done for everyone else (Dhingra &
Sampson, 2016). The tariff that applies to the ‘most-favoured nation’ (MFN) must
similarly apply to all. In practice, this would prevent discriminatory or punitive tariffs
being levied by the EU on the UK, or vice versa. The maximum tariff would be that
applied to the MFN. The EU’s MFN tariffs have generally fallen over time, meaning that
in this particular context the ‘advantage’ of EU membership has declined. Trading on
these terms would mean many UK exporters to the EU becoming less price competitive,
to varying degrees, than their counterparts operating within the remaining EU, and those
within countries with which the EU has preferential trading relationships (Webb, 2017)
The UK would also need to decide the level of tariffs on imports into the EU. Under
WTO rules, the UK would not be able to discriminate between imports from different
countries, except where there was a free trade agreement. Setting the level of tariffs would
involve a tradeoff between lower prices for domestic consumers on the one hand, and
bargaining power in future trade negotiations on the other (Mandal, 2017) Setting
relatively high tariffs would increase prices for consumers but give a bargaining chip in

21
future negotiations. Eliminating or setting low tariffs would tend to reduce prices, but
give trading partners little incentive to reduce their tariffs in any future negotiations. The
Government has announced that it intends to replicate the EU’s tariff structure, as far as
possible, at least initially. Non-tariff barriers to trade include, for example, differing
product standards. These might be in the areas of labelling, packaging and sanitary
requirements (Miller, 2016)

Movements of services

Trade in services would be governed by the WTO’s 1995 General Agreement on Trade in
Services (GATS) – a very limited form of integration. Under WTO rules, the financial
sector may lose special allowance, by which UK firms can do business in the rest of the
EU without having to go through the lengthy and costly process of acquire authorization
from each individual member state (Green, 2017) Under this agreement, all WTO
members again have to respect the principle of non-discrimination, and varying levels of
binding liberalization commitments are made by WTO members in individual services
sectors. As a ‘stand-alone’ WTO member, the UK would be faced with the same level of
access to the EU services market as all other WTO members in line with the EU’s GATS
commitments – a much lower degree of access to the free movement of services which is
a central facet of the Single Market enshrined in the EU Treaties

Trading ability with EU members

The EU has an extensive network of trade agreements of various types with around 50
countries. Some are comprehensive free trade agreements such as the FTAs with
Canada, , Chile, Mexico and Korea. Once the UK exits the EU, the existing EU FTAs will
no longer be applicable to the UK. This means that the UK will lose preferential market
access to the EU’s partner countries (Nicolaides & Roy, 2016). It has been suggested that,
under international law, the UK could potentially remain a party to some of the EU FTAs
post Brexit. However, being outside the Single Market would enable the UK government
to set economic policy and regulatory standards without taking account of the preferences
of other EU members (Dhingra & Sampson, 2016). But any divergence in regulation
between the UK and the EU would still act as a non-tariff barrier to trade and raise the
22
cost of doing business with Europe. Therefore, the UK would receive their full power to
negotiate with each members of the EU as well as other nations around the world.

Movements of people and contribution to the EU budget

The WTO has no provisions for free movement of labor, so under this scenario, free labor
mobility between the UK and the EU would cease (Dhingra et al, 2017)

Therefore, it could be implied that the UK would control the immigration. Leaving the
EU would mean that the UK would no longer have to contribute to the EU’s budget,
saving the country £7.3bn a year since the cost of EU tariffs on UK exports (excluding
agriculture) would be only around £3.5 billion a year - about 0.5% of Government
spending and a minority of the £10-£11 billion net dividend the UK will receive from no
longer making its annual EU budget contribution (Minford & Miller, 2016).

Summing up, the UK could find itself, for the first time since the 1970s, back to facing
tariff discrimination vis-à-vis other European countries in the EU market. The trade
effects could be very substantial. However, this assumes that are once a trade effect is
established it is unlikely to be quickly reversed. A hysteresis or ‘beachhead’ effect could
maintain many existing trade links even if new trade is impeded. Nonetheless the damage
to UK-EU trade could be severe, especially under hard Brexit where no special
arrangements are negotiated. Robert Hine (2017) come to the alarming conclusion that
even under the optimistic scenario that the UK negotiates a free trade agreement with the
EU, UK incomes could fall by between 6.3% and 9.5%.42 This would certainly add
urgency to the negotiation of better access to non EU markets.

4.2. Free Trade Agreement (FTA) option

The fourth option available to the UK would be to negotiate a free trade agreement with
the EU. Such an agreement would probably result in most goods and services flowing
freely between the UK and the EU, while a number of non-tariff barriers and regulatory
barriers could also be removed.

A step forwards, but really close to the Hard Brexit will be the model of a Free Trade
Agreement between the UK and the EU. This will create a closer integration within the
23
continent, avoiding the comeback to the WTO tariffs at least for the EU or other
Countries which will negotiate something similar. Free Trade Agreement option would be
to establish a FTA arrangement, as with the Comprehensive Economic and Trade
Agreement (CETA) that the EU has negotiated with Canada eliminates all tariffs on
mutual trade. In practice, going with as deep an FTA as possible with the EU really makes
sense, with all the constraints outlined above, and then try to sign as many bilateral trade
agreements with non-EU countries as possible.

Movements of goods

Trade between the EU and Canada is bound by Rules of Origin. This means that Canadian
companies have to prove that a sufficient proportion of the product was originally made in
Canada in order to qualify for preferential tariff rates. Complying with these rules creates
an extra burden for businesses (Patrick Georges, 2017). Currently UK companies do not
have to meet this requirement when trading with the EU. A standard FTA could ensure
that after Brexit there would continue to be low tariffs on goods trade between the UK
and EU. With goodwill, a FTA agreement could be made at an early stage in negotiations
to reassure they will generally retain tariff-free access to EU markets (Robert Hine, 2017) .
This might seem more advantageous to the UK than the EU in terms of relative trade
shares.

Movements of services

Inside the EU, the UK stands to benefit from further liberalization of the Single Market.
Services under plans drawn up by the current European Commission. As mentioned by
HM Government (2016) if all the EU’s national services markets were as open as the top
five performing European markets, this would add 2% to the UK’s GDP. The EU-Canada
Trade Agreement offers more limited liberalization. The EU will open its market in
services significantly for Canadian firms. Similar terms to the EU-Canada Agreement
would have an adverse impact on this balance as our trade would be affected. The access
to the Single Market will not allow the UK to set its own rules, having to respect the EU
regulation to not create non-tariff barriers. Indeed, CETA annexes are listing hundreds of
reservations to free cross-border access in services and other modes of services delivery.
24
If the UK would adopt the same model, its exporters would be exposed to a raft of new
restrictions such as economic-need tests. Moreover they will lose the full right to post
intra-corporate transfers in all sectors where EU member states have not agreed to full
liberalization.

Movements of people, trading ability with EU members and contribution to the EU

budget

According to European Parliament (2018), the UK would gain the independence in

policymaking, as the trade agreement without any binding obligations to follow EU
regulations. Confirming the current level of harmonized or mutually recognized technical
regulations will help to maintain the trade easy without barriers. The right to use trade
remedies and state aid (which are actually forbidden in Europe) would be reintroduced if
Britain leaves. CETA does this without requirements in relation to free movement of
persons, contributions to the EU Budget. Only a high level or temporary immigration
would be allowed. No contribution will be sent to the EU, keeping all the money of tax in
the UK (KAROLINA BOROŃSKA-HRYNIEWIECKA et al, 2016)

4.3. Custom Union Access option

Another potential option for the UK upon leaving the EU would be to adopt a Customs
Union with the EU’s Customs Union. Though not actual membership of the Customs
Union, this approach would provide Single Market access for UK goods in the areas
covered by the Customs Union agreement (Ronek, 2016). An example of this approach is
Turkey which adopted a relationship with the EU’s Customs Union in December 1995. If
the UK stayed in the Customs Union, but left the Single Market, it would have to comply
with the terms of EU free trade agreements in goods but these would not compensate for
the loss of access for services which is the largest sector of the UK economy (Piris, 2016).

Movements of goods

The fundamental point is that a Customs Union is a trade bloc where the partner countries
agree to remove tariff barriers on each other’s goods and to have a common external tariff
against third countries, whereas a free trade agreement is where countries agree to remove

25
tariff barriers on each other’s goods but they do not have a common policy against third
countries. The consequence is that within a free trade agreement you have to have
customs barriers to check whether a product really comes from the partner or whether it is
a third-country good, in which case it is not entitled to duty-free access (Mirus & Rylska,
2001). With a free trade area, you have to have rules of origin to check whether a product
originated within the free trade area. With a Customs Union, in principle you do not have
to have rules of origin, so the goods can flow completely freely (McIver & Berthier,
2016). A customs union with the EU similar to Turkey’s arrangement would require the
UK to adopt the EU’s standards and regulations for all goods under the customs union
arrangement.

Movements of services

The advantages for goods trade do not necessarily apply to services however. Services are
not usually directly affected by customs unions as it is non-tariff barriers to trade (such as
regulatory requirements on establishment, the need for recognized professional
qualifications etc.) that restrict cross border trade in services. Holmes (2016) explained
that while customs union models shared the benefit of “countries agree to remove tariff
barriers on each other’s goods,” (McIver & Berthier, 2016). Customs unions principally
eliminate tariffs, and so do not directly facilitate trade in services, which often face non-
tariff barriers. The customs union did not have direct implications for services.

Movements of people

In particular, the UK would have full control over its immigration policy. However, UK
citizens would equally lose the right to travel and work freely in the EU. It may be that no
EU budget contributions would be required, although this would have to be negotiated.
75% of customs duties collected when a good is imported into the EU goes into the EU
coffers, and this accounts for 20% of the EU budget. Thus, in return for a customs union
with the UK, the EU might ask for a contribution to replace the lost revenue (Edmans,
2017) Turkey was not granted free movement of people when the customs union
agreement negotiated.

Trading ability with EU members and contribution to the EU budget

26
The UK would be unable to sign its own free trade agreements with other countries in
areas covered by a customs union agreement. A key feature of a customs union is that all
members charge the same set of tariffs on imports. The UK would therefore be bound by
EU tariffs if it were in a customs union with the EU since Turkey must accept imports
from those countries on FTA terms where the EU has free trade agreements with third
countries (Webb, 2018) According to Karatas (2016) being part of any customs union
came at a price: completely lose ability to have an own independent external trade policy
with third countries. In areas covered by its customs union, Turkey had to have exactly
the same external trade policy as the EU. Pressure is on Turkey to sign agreements with
countries that the EU has signed with areas covered by the customs union.

So the advantage of the Customs Union is that you get complete exemption from tariffs
for all goods across the border, but in principle you have to have exactly the same external
trade policy as your partner, which means that Turkey has to sign free trade agreements
with everybody that the EU signs an agreement with. It has, in principle, to accept any
negotiating outcomes that the EU secures at the WTO. If there ever is another WTO
round, Turkey will have to go along with the EU position. Basically, in a Customs Union,
the UK could completely lose ability to have its own independent external trade policy.
But as this paper has explained there are difficulties in the UK remaining in the EU
Customs Union, including the lack of preferential access to the EU for services; the need
to be bound by third country agreements negotiated by the EU without having any say in
their negotiation; the restrictive effect on the UK’s ability to negotiate trade agreements
with third countries; and the need to make payments into the EU budget. As the Prime
Minister has said that these latter requirements are an obstacle to the UK remaining in the
EU Customs Union, the UK will aim to negotiate arrangements acceptable to it and to the
remaining Member States and which are compatible with the UK’s obligations as a
member of the WTO (White, 2017).

As a result of its agreement with the Custom’s Union, Turkey is required to align its
external tariffs with those of the EU. This means that when the EU concludes a trade
agreement with a third country, in areas covered by its Customs Union membership

27
Turkey is required to provide access to its market on the same terms as those agreed by
the EU.

4.4. European Free Trade Association (EFTA) option

EFTA was formed to promote a strengthening of economic relations and also provides an
enhanced common platform for developing relations with trade partners around the world.
EFTA today maintains the management of the EFTA Convention (intra-EFTA trade), the
EEA Agreement (EFTA-EU relations), and the EFTA Free Trade Agreements (third
country relations). The EEA entered into force on 1 January 1994, extending the Single
Market of the European Union to three of the EFTA countries: Iceland, Liechtenstein and
Norway. The EEA Agreement extends the four freedoms which are movement of goods,
services, capital and persons) to the EU member states and vice-versa (Kocak, 2016).

Movements of goods and services

The core benefit of this model is that it would allow the UK to retain unfettered access to
the EU Single Market. EFTA ensured the four freedoms, the free movement of goods,
services, capital and persons, within its members. As first, it set a free trade area between
the members, eliminating the customs duties on imports and exports. The service market
apply similar rules, restrictions on the right to supply services within the territory of the
Members are forbidden (Carpenter & Floater, 2002). EFTA currently has 25 FTAs with a
total of 35 partners outside the EU, and other negotiations have been concluded or are in
advanced progress. The EFTA is also reviewing and comprehensively updating a number
provide for a framework of dialogue and cooperation towards closer trade and investment
relation. This option would retain most of the trade advantages in the EU market now
enjoyed by UK exporters of goods and services (Cottier, 2013). Moreover there are
precedents since the EU has already granted this arrangement to neighboring countries.
The EFEA gives its non-EU members a high level of access to the Single Market.

Contribution to EU budget

Critics to the model is the price to pay will be the contribution to the EU budget, which is
however basically contributed to the EU project involving also the UK, and to the EFTA

28
budget. Under similar circumstances, the UK, given its size, would probably pay between
2.5 billion and 4 billion euro a year, which is close to half of its current net contribution
the EU budget. Avoiding to contribute to the EU budget is one of the reason of the Leave,
such an agreement would so be contested (Chomicz, 2017).

Movements of people and trading ability with EU members

Added to the loss of sovereignty for EFTA members, is an acceptance of free movement
of persons. Under the EFTA, member states allow their citizens to freely move among the
other Member States, ensuring them also the possibility to find an employment, thanks to
the mutual recognition of professional qualifications. The UK could try and seek
safeguards on migration or specific mechanism to help manage it. However, the EU was
unwilling to concede a Liechtenstein-style emergency brake to the UK while it was
a member, and is more likely to insist that the UK uses domestic measures to manage
migration (Emerson, 2016).

4.5. Comparison between scenarios

Since each trade option has been carefully investigated, the comparison need to be
operated in order for the most suitable model to be found. Analysis from each areas of
movement of goods, services, people, third countries trade policy and contribution the EU
among each scenarios are going to be constructed.

Movements of goods

In the term of movements of goods, the WTO option offers high tariffs under the
Organization rules in the exchanges between the UK and the EU since the Single Market
are no longer British advantage in the European market. The tariff that applies to the
MFN apply to all countries in the WTO and could be reduced over time. However, the
tariff also imposes in the import and export goods; therefore, no nation would want to
receive less tariff contribution from exports and give away more from imports. For the
FTA scenario, trade between the EU and Canada is bound by Rules of Origin and the
tariff could be set at a low number. Move to the choice of Customs Union, the goods can
flow completely freely. A customs union with the EU similar to Turkey’s arrangement

29
would require the UK to adopt the EU’s standards and regulations for all goods with the
access to Single Market. For the last option, it is said that the core benefit of this model is
that it would allow the UK to retain access to the EU Single Market. EFTA ensured the
four freedoms, the free movement of goods, services, capital and persons, within its
members. Consequently, goods would be traded freely among members of EFTA
including the UK itself.

WTO option FTA option Customs Union EFTA option

option

No tariff  

Low tariff 

High tariff 

Table 1. Movements of goods in each scenario

Movements of services

Under WTO rules, the services sector may lose special allowance, by which UK firms can
do business in the rest of the EU without having to go through the lengthy and costly
process of acquire authorization or it can be said that British companies could face
complicated barrier from each individual member states. If a FTA is set, the EU will open
its market in services significantly for the UK firms but it offers limited liberalization.
The access to the Single Market create non-tariff barriers between members, now, since
the EU membership has been collapsed, a limited movement of services for the UK is
acceptable. Even though free flow of goods is achieved in Customs Union model, the
advantages for goods trade do not apply to services. The four freedoms, the free
movement of goods, services, capital and persons, creates a convenient flow in goods for
the UK to the EU.
30
 WTO option FTA option Customs Union EFTA option
option

Free  

Limited

liberalization

Complicated

barrier

Table 2. Movements of services in each scenario

Movements of people

The WTO has no provisions for free movement of labor, so under the scenario, the UK
would control the immigration. It could be inferred the movement of people is not
negotiated since advancement for immigration is not included in the FTA vision. In
particular, the UK would have full control over its immigration policy. The UK would
have full control over its immigration policy also if Customs Union choice becomes
reality. Under the EFTA, member states allow their citizens to freely move among the
other Member States and ensure them also the possibility to find an employment which
cause the loss of sovereignty for the UK while immigration could not be controlled.

WTO option FTA option Customs Union EFTA option

option

Yes  

31
No  

Table 3. Movements of people in each scenario

Trading ability with EU members

According to the departure of the UK, the country would receive their full power to
negotiate with each members of the EU as well as other nations around the world for the
WTO option as no prohibition from the EU is set for non-members. The same advantage
would belong to the UK if the FTA model is chosen. Difference appears in Customs
Union model since UK would be unable to sign any agreements with other countries in
the areas covered by a customs union agreement. Similar to the Custom Unions version,
EFTA does not allow their members to negotiate agreement to others. The decision is
understandable since the Single Market also set a prohibition on EU nations in dealing
with each others.

WTO option FTA option Customs Union EFTA option

option

Yes  

No  

Table 4. Trading ability with EU members in each scenario

Contribution to the EU budget

Leaving the EU would mean that the UK would no longer have to contribute to the EU’s
budget, all the money of tax would be kept in the UK for WTO and FTA model. With the
scenario of Customs Union, EU budget contributions may not be required, nonetheless,
need negotiating since the EU might ask for a contribution to replace the lost revenue.
Since the four freedoms is met in EFTA model, contribution to the EU budget is required.

32
 WTO option FTA option Customs Union EFTA option
option

Yes 

Need to be

negotiating

No  

Table 5. Contribution to the EU budget in each scenario

As mentioned, the ultimate aim of negotiation period is collecting full access to the Single
Market, which is a place of free movements of goods and services, trading ability among
the EU members, without making any contributions and allowing immigration from the
EU. Each model has been analyzed:

- WTO option contains no free movement of goods with high tariff, no free
movement of services with complicated barrier among the EU members but trading
ability among these nations is attached. No contribution must be made and
immigration is not allowed.
- FTA option contains no free movement of goods with low tariff, no free movement
of services with limited liberalization among the EU members but trading ability
among these nations is attached. No contribution must be made and immigration is
not allowed.
- Customs Union option contains free movement of goods and services among the
EU members but trading ability among these nations is not attached. Contribution
could not be obliged but need to be negotiated and immigration is not allowed.

33
 - EFTA option contains free movement of goods and services among the EU
members but trading ability among these nations is not attached. Contribution must
be made and immigration is not allowed.

Due to the summarized list, the WTO option meets 3 out of 5 criteria, the FTA meets 3
out of 5 criteria, the Customs Union could meet 3 out of 5 criteria with the promised 2
and the EFTA meets 3 out of 5 criteria. With the final result, the most suitable scenario
for the UK trade is difficult to be decided.

34
 CHAPTER V. CONCLUSION

In conclusion, the thesis aims at providing knowledge about the possible trade
arrangement between the UK and EU after Brexit. Information extracted from a wide
range of books, previous research and journals in this field are also illustrated in order to
give readers a broader view of these relationships

First , There could be four possible relationships for the EU and the UK which are
the World Trade Organization (WTO) option, the Free Trade Agreement (FTA) option,
the Customs Union option and the European Free Trade Association (EFTA). Each
relationship based on trade arrangements which the EU or the UK are involved.

Second, with the final result referred from the comparison, the most suitable
scenario for the UK trade is difficult to be decided since each possible arrangement
contains its own advantages and disadvantages. Therefore, a more comprehensive
research should be done in order to discover the best option.

35
 REFERENCES

Brexit: Option for trade,” (2017). Retrieved from

https://publications.parliament.uk/pa/ld201617/ldselect/ldeucom/72/72.pdf

Implications of the leaving the EU single market. (2017). Retrieved from

https://www.ukfinance.org.uk/wp-content/uploads/2017/09/BQB1.pdf

Understanding the WTO. (1995). Retrieved from

https://www.wto.org/english/thewto_e/whatis_e/tif_e/understanding_e.pdf

Alter, K. & Steinberg, D. (2007). The Theory and Reality of the European Coal and Steel
Community. Retrieved from
https://pdfs.semanticscholar.org/9682/1d9138ce81ade3c2b46fd8683c70c96b33c8.pd
f

Brunazzo, M. & Settembri, P. (2010). Burial or resurrection? The fate of EU “pillars”

after Lisbon. Retrieved from https://www.sisp.it/files/papers/2010/marco-brunazzo-
e-pierpaolo-settembri-752.pdf.

Clark, N. (2008). Not so suicidal after all. Retrieved from

https://www.theguardian.com/commentisfree/2008/jun/10/labour.margaretthatcher

Cooper, M. (2016). The “romantic” and “distorted” language of campaigners who want
Britain to leave the EU. Retrieved from https://qz.com/703078/language-experts-
say-the-rhetoric-of-campaigners-who-want-britain-to-leave-the-eu-is-romantic-and-
distorted/

Deloy, C. (2016). 43 years after their accession Britons decide to leave the European
Union. Foundation Robert Schuman. Retrieved from https://www.robert-
schuman.eu/en/doc/oee/oee-1652-en.pdf

36
Dhingra, S & Sampson, T. (2016). Life after BREXIT: What are the UK’s options outside
the European Union. Retrieved from
http://cep.lse.ac.uk/pubs/download/brexit01.pdf .

Grønningsæter, T (2013). The EEA Agreement – Background, Developments and

Challenges. EFTA Seminar on the EEA Agreement. Retrieved from
https://www2.le.ac.uk/departments/politics/documents/centre-right/
UKIPCandidatesandSupportersworkingpaper-1.pdf

Hunt, A. & Wheeler, B. (2018). Brexit: All you need to know about the UK leaving the
EU. Retrieved from http://www.bbc.com/news/uk-politics-32810887

Huet, P. G. (2014). European Integration Theories: The Case Of EEC Merger Policy.
Retrieved from http://etheses.lse.ac.uk/2615/1/U615564.pdf

Karatas, I. (2016). The EU-Turkey Customs Union: Towards a Revision of the Legal and
Institutional Framework? Universiteit Gent. Faculty of Law . Retrieved from
https://lib.ugent.be/fulltxt/RUG01/002/304/294/RUG01-
002304294_2016_0001_AC.pdf.

Khorana, S. (2015). The Transatlantic Trade and Investment Partnership (TTIP)

Negotiations between the EU and the USA. Retrieved from
https://www.google.com.vn/url?
sa=t&rct=j&q=&esrc=s&source=web&cd=1&ved=0ahUKEwiwwfzdlpbbAhUBjZQ
KHX5_C9YQFgglMAA&url=https%3A%2F%2Fwww.cidob.org%2Flayout%2Fset
%2Fprint%2Fcontent%2Fdownload%2F62536%2F1947315%2Ffile%2FThe
%2BTransatlantic%2BTrade%2Band%2BInvestment%2BPartnership
%2B(TTIP).pdf&usg=AOvVaw02kdaZocFalfdM4v0J8BN8

KESNER-ŠKREB, M. (2010). The European Union Customs Union. Institute of Public

Finance, Zagreb. Retrieved from https://hrcak.srce.hr/file/75506.

Meyer, J. (2016). The 1975 referendum on Britain’s continued membership in the EEC.
Université Humboldt de Berlin. Retrieved from Moseley, T. (2016). The rise of the
word Brexit. Retrieved from http://www.bbc.com/news/uk-politics-37896977
37
Miller, V. (2015). The 1974-1975 UK Renegotiation of EEC Membership and
Referendum. House of Commons Library. Retrieved from
http://researchbriefings.files.parliament.uk/documents/CBP-7253/CBP-7253.pdf

Negadi, A. (2017). The European Union and the United Kingdom’s Withdrawal.
University of Tlemcen. Faculty of Letters and Languages. Retrieved from
http://dspace.univ-tlemcen.dz/bitstream/112/11417/1/abdallah-negadi.pdf

Owen, J., Stojanovic, A. & Rutter, J. (2017). Trade after Brexit Options for the UK’s
relationship with the EU. Institution for Government. Retrieved from
https://www.instituteforgovernment.org.uk/sites/default/files/publications/
IFGJ5896-Brexit-Report-171214-final_0.pdf

Rentoul, J. (1995). Sir James prepares to take on the world. Retrieved from
https://www.independent.co.uk/news/uk/sir-james-prepares-to-take-on-the-world-
1579525.html.

Salmaso, A. (2016). A Soft Brexit: Analysis Of The Referendum Outcomes And Future
Possible Scenarioss. Retrieved from
https://www.researchgate.net/profile/alfredo_salmaso/publication/311980964_a_soft
_brexit_analysis_of_the_referendum_outcomes_and_future_possible_scenarios/
links/588e2af7a6fdcc8e63cac2c0/a-soft-brexit-analysis-of-the-referendum-
outcomes-and-future-possible-scenarios.pdf?origin=publication_detail

Smith, J. (2016). David Cameron’s EU Renegotiation and Referendum Pledge: a Case of

Déjà vu. Retrieved from
https://www.repository.cam.ac.uk/bitstream/handle/1810/256243/Smith-2016-
British_Politics-AM.pdf?sequence=1

Soares, A. (2017). The negotiations for the UK’s withdrawal from the European Union.
Retrieved from http://crossborder.ie/site2015/wp-content/uploads/2017/08/CCBS-
Report-The-negotiations-for-the-UKs-withdrawal-from-the-European-Union1.pdf

38
Sorokina, M. (2014). Great Britain and the European integration. Masaryk University.
Faculty of Social Studies. Retrieved from
https://is.muni.cz/th/404812/fss_m/Master_Thesis.pdf

Tickell, C. (2016). How Britain negotiated its entry to the EEC – then failed to play its
part. Retrieved from https://www.theguardian.com/politics/2016/jun/25/how-britain-
negotiated-its-entry-to-the-eec-then-failed-to-play-its-part

Winders, S. (2016). Brexit and Free Trade. Retrieved from

https://www.brugesgroup.com/images/papers/brexitandinternationalfreetrade.pdf

Walker, N. (2018). Alternatives to a no-deal outcome in negotiations with the EU.

Number CDP-0039. House of Commons Library. Retrieved from
http://researchbriefings.files.parliament.uk/documents/CDP-2018-0039/CDP-2018-
0039.pdf

Webb, D. (2017). Brexit: trade aspects. Retrieved from

http://www.europarl.europa.eu/meetdocs/2014_2019/documents/deea/dv/8-1-brexit-
trade_20170209_/8-1-brexit-trade_20170209_en.pdf.

Whitaker, R. & Lynch, P. (2011). The UK Independence Party: Analysing its candidates
and supporters. Retrieved from
http://www.efta.int/sites/default/files/documents/eea/seminars/eea-lux-s16/Holter-
Gronningsaeter-EEA-EFTA.pdf

39