Following some recent seminars and workshops I have presented please see below a table which illustrates the various Brexit options – these assume that the Withdrawal Bill will go through in some form. This is text is based on the current information we have and our best assumptions at the time of writing.
| Options | Transition/start period | What does this actually mean as a very brief summary? |
| Single Market (Norway) EEA European Economic Area – Join EFTA sign up to EEA. | December 2020 Earliest | Rules of origin would apply (see section under Canada FTA) but the UK would stay fairly integrated with the EU on many issues such as conformity and service sector would have access to the single market. Free movement of people would remain. However, some in the UK see this option as being Brexit in name only as we would need to continue to pay into the EU. |
| Custom Union/Partnership | December 2020 Earliest | Goods would move freely around the EU regardless of origin – this is favoured by most Automotive and manufacturing It is not favoured by many who want Brexit as it would mean the UK would still be a rule taker and unable to set its own tariffs and FTAs. However, the UK would also Keep access to current FTAs through the EU (over 50) including Turkey, South Africa, Mexico, Japan and Canada. There will still need to be a customs entry of some sort, But this may be simplified. |
| Canada FTA (Model) | Depends / Probably until December 2020 earliest | Favoured by most Brexiteers, most originating products would be duty free and rules of origin would become very important – non originating goods i.e. US/Chinese would be treated as third country unlike in a customs union therefore double duty may have to be paid on re-export / import to from the EU and customs declarations will be implemented. |
| No Deal Brexit | WTO Rules from 30th March 2019, if there is no agreement on the withdrawal bill before the 29th March then we will trade on WTO rules from this date. | WTO Rules from 30th March 2019, if there is no agreement on the withdrawal bill before the 29th March then we will trade on WTO rules from this date. What does this actually mean as a very brief summary? Rules of origin would apply (see section under Canada FTA) but the UK would stay fairly integrated with the EU on many issues such as conformity and service sector would have access to the single market. Free movement of people would remain. However, some in the UK see this option as being Brexit in name only as we would need to continue to pay into the EU. Goods would move freely around the EU regardless of origin – this is favoured by most Automotive and manufacturing It is not favoured by many who want Brexit as it would mean the UK would still be a rule taker and unable to set its own tariffs and FTAs. However, the UK would also Keep access to current FTAs through the EU (over 50) including Turkey, South Africa, Mexico, Japan and Canada. There will still need to be a customs entry of some sort, But this may be simplified. Favoured by most Brexiteers, most originating products would be duty free and rules of origin would become very important – non originating goods i.e. US/Chinese would be treated as third country unlike in a customs union therefore double duty may have to be paid on re-export / import to from the EU and customs declarations will be implemented. This option would apply if the EU/UK cannot agree on the withdrawal bill between now and the 29th March 2019. (this could be extended) Very few businesses want this option and this would result in the UK trading with the EU under third country WTO Rules Due to the 40+ history of integration between the UK/EU, this would have a major impact on businesses in both the UK and EU in a very short space of time. However, even if the UK /EU agree to the withdrawal bill before the 29th March 2019 but still fail to put in place a deal during the transition period then the UK could still leave the EU with no deal again not a welcome outcome for most international businesses |