Why it’s a mistake to talk about a ‘Swiss-style’ post-Brexit UK-EU deal

We struggle to grasp unfamiliar detail and nuance. So we invent labels and waste time and energy debating what they mean

Screenshot of the third slide of "The bilateral approach’" showing Switzerland surrounded by the EU and little icons scattered over the EU representing over 100 agreements

By Peter Ungphakorn

Maybe it was because someone thought it would be a good idea to stick a label on where UK-EU relations might be heading now that the atmosphere between the two is widely reported to have improved. Or perhaps it was just because people were bored while waiting for the football World Cup to start.

Whatever the reason, “Swiss-style ties with Brussels” suddenly became big news over the weekend after the Sunday Times reported (November 20, 2022, paywalled, but some more detail here) that the British government is considering exactly that.

Reactions ranged from “Doubt it. EU hates its relationship with Switzerland & Switzerland hates its relationship with EU” (Mujtaba Rahman, here), to “when someone says ‘Swiss-style’ relationship, rather than hearing ‘a slightly better relationship [than] now’ everyone is like ‘LET ME GET MY NOTES’” (Sam Lowe, here).

The problem here is that “Swiss-style” is being used as shorthand. It’s a label, but one that’s misleading and not really explained. Both of the reactions above are valid, at least to some extent, but they are talking about different things.

This is happening because we struggle to grasp unfamiliar detail and nuance. So we invent simple labels. Like “right-wing” and “left-wing”. Like “neoliberal” or “neo-Keynesian” or even “post-neoliberal”. We then waste immense amounts of time and energy debating what they mean.

“Swiss-style” was a misguided attempt to sum up what might happen in a complex UK-EU relationship. (So is the related debate about the UK “joining” the EU Single Market.)

The article doesn’t tell us much about what the proposed new negotiations will be about or what they will do. Until we know that, there’s little point in passing judgement

It sounded like copying the Swiss-EU relationship (more below), but that was almost certainly not what it was about. Both the UK government and the EU would object, but for different reasons.

The Sunday Times article even says the talks would exclude freedom of movement of people, which is an important part of the Swiss-EU relationship. (Even that is nuanced, but let’s not go there.)

What the Sunday Times’ sources seem to be saying is that the British government’s idea is for London and Brussels to negotiate more agreements on a range of subjects, in order to reduce trade barriers further than under the present Trade and Cooperation Agreement. Or to move into other areas like security.

An extension of the “Swiss-style” confusion is another label — about being a “member” of the Single Market (or “in” it).

The only true members of the EU Single Market are EU members. The Single Market is an internal market. The EU uses the terms interchangeably.

Trade between Manchester and London is within the UK’s internal market.

In the same way, trade between Frankfurt and Munich is within Germany’s internal market. More importantly Germany’s internal market is also part of the EU’s internal market. Trade between Frankfurt and Madrid is the same as between Frankfurt and Munich. The only difference is distance.

Trade between Oslo and Frankfurt is not internal. There are customs and other border processes. Rules of origin apply — goods shipped from Oslo are treated differently depending on whether they are considered to have been “made in Norway” or not.

So Norway is not a “member” of the EU Single Market even though it is in the European Economic Area. It is not “in” the Single Market either. But it has easy access and is closely integrated.

For all countries that are not EU members, there’s a sliding scale of how easy it is to access the EU’s single internal market. At one end are Norway and Iceland, followed by Switzerland. At the other is North Korea. None of them is a member of the Single Market or fully “in” it.

(Some are speculating that the incentive might be to sort out the Northern Ireland protocol in the Brexit agreement, but again, let’s not go there.)

In other words, “Swiss-style” is being used to mean an unspecified number of new agreements that (hopefully) improve on the present relationship — but nowhere near the number or coverage of the Swiss-EU agreements, not for a long time at least.

Even more hopefully, perhaps it means that some of the British government’s old red lines will be removed, for example on aligning (if not adopting) safety and other standards on goods.

There’s nothing particularly “Swiss” about adding new deals to an existing one.

The EU and Japan have six important economic and trade agreements and another one on a strategic partnership which envisages future “enhancements” on a wide range of subjects. Many of the UK’s trade agreements have future negotiations built in.

The world doesn’t stand still. We would expect the UK and EU to negotiate improvements in their trade relations in the future anyway, so long as sanity prevails.

Calling new agreements “Swiss-style” is just unhelpful. It waves a big red flag with a white cross in front of several bulls — Brussels itself and vocal Eurosceptics.

The other problem with the Sunday Times article is that it doesn’t tell us much about what the proposed new negotiations will be about or what they will do.

Until we know that, there’s little point in passing judgement.

Except …

The Swiss-EU relationship

Except we can be certain that this is not about replicating the Swiss-EU relationship. That’s clear from a quick glance at what that relationship is.

Switzerland is completely surrounded by the EU — France, Germany, Austria and Italy — except for a little dot called Liechtenstein. A large amount of trade also crosses Switzerland, between Germany and Italy and elsewhere. For centuries those Alpine passes were vital. Now it’s tunnels under the mountains.

The agreements Switzerland has reached with the EU have accumulated over decades. There are now well over 100.

They have become so complicated that the EU wants a change, by packaging all the agreements under a single framework. Common issues, like legal challenges, would all be handled in one place. The Swiss don’t object. For them the problem is some parts of the content.

After years of negotiation, the Swiss rejected the framework in 2021. Among the sticking points: salary protection, state aid rules, and the access of EU citizens to Swiss social security benefits.

More recently, Bern has been more optimistic, saying a deal is possible, but with another set of bilateral agreements and not an overall framework agreement. What comes of that remains to be seen.

The present list of agreements — containing only their titles and reference numbers — is extraordinarily long. For example the list in French (downloaded November 21, 2022) is 31 pages. Details and other languages are available here.

This is the start of the list in French:

Screenshot of the start of the list of Swiss-EU treaties, in French
Swiss-style: first page of the list of over 100 Swiss-EU treaties

The main subjects of the agreements (listed on this page) are:

Clearly the British government does not envisage covering all of that. Not even a lot of it.

Summary slides

For a closer look at the detail, the Swiss government has basic explanations in two sets of slides, both downloaded from this page on November 21, 2022.

‘The bilateral approach’

18 slides on the background and the thinking behind the Swiss approach to the EU

Screenshot showing the subjects and results of 12 referendums, 1992–2022
Key referendums: slide 6 from The bilateral approach
‘The main bilateral agreements between Switzerland and the EU’

33 slides on the main agreements from the four periods

Screenshot of the title page, The main bilateral agreements between Switzerland and the EU
The main agreements: 27 subjects in four periods, The main bilateral agreements between Switzerland and the EU


Here’s a Twitter thread three days later by Mujtaba Rahman

December 5, 2022 — Adding the sidebar box on Single Market membership
November 23, 2022 — Adding the P.S. with the Twitter thread
November 22, 2022 — Minor edits

Image credits:
Screenshots of slides on Swiss-EU relations | Federal Department of Foreign Affairs, Bern


Author: Peter Ungphakorn

I used to work at the WTO Secretariat (1996–2015), and am now an occasional freelance journalist, focusing mainly on international trade rules, agreements and institutions. (Previously, analysis for AgraEurope.) Trade β Blog is for trialling ideas on trade and any other subject, hence “β”. You can respond by using the contact form on the blog or tweeting @CoppetainPU

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