What are disadvantages of joining European Free Trade Association (EFTA) and negotiating deals similar to the ones between the EU and Switzerland?

It would eliminate the need for a hard border in Northern Ireland (important for supporters of a soft Brexit), let the UK negotiate its own trade agreements and give it control over freedom of movement by making it subject to bilateral agreements (important for supporters of a hard Brexit).

Yet, the indicative votes have shown that this the least supported option in the British parliament. I understand why remainers oppose it, but why is it also opposed by so many Brexiteers?

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    The premise of your question is incorrect. The UK's joining EFTA would by itself not allow an open border between Northern Ireland and the Republic of Ireland, because they would continue to be separate customs territories, and customs controls would be necessary, just as there are customs controls at Switzerland's borders.
    – phoog
    Apr 22, 2019 at 1:15
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    @phoog I wrote it would eliminate the need for a hard border. I've crossed the Swiss border a few times, and however one might call this arrangement, it's definitely not a hard border.
    – michau
    Apr 22, 2019 at 2:24
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    Whatever adjective you use to describe the border or the border control arrangements, there is only one sort of border control that will be required as a consequence of the UK leaving the EU, and that is customs controls. Free trade agreements do not remove the need for customs controls; only a customs union does that. There's no reason the Irish border couldn't look like the Swiss border even after a no-deal Brexit. Yet that is the very situation that is deemed unacceptable by so many, and the UK joining EFTA would not change that.
    – phoog
    Apr 22, 2019 at 3:14

2 Answers 2


According to the slides by Michel Barnier (also printed below), the 'Switzerland option' has certain requirements that may not fit with UK red lines.

I will quote the point from the slide, which are possible UK red lines, and say how these could be overcome to make the Switzerland option work.

  • No free movement. To overcome this, the UK must give in that it cannot block free movement of people. In the Swiss case that's covered by this agreement.

  • No substantial financial contribution. To overcome this, the UK would have to contribute to the EU budget. Consider this article on the website of the Swiss confederation.

  • Regulatory autonomy. To overcome this, the UK has to implement some EU laws to have and maintain EU market access. For the Swiss case, consider this page by fullfact.org.

Slide about UK options

As requested in the comments, the figure needs some guidance. To read the graph, you start on the left. Being an EU member is the most aligned you can be with the EU. Underneath that there is a red line, if you don't want to be an EU member the next most aligned option is one step to the right. That also comes with red lines from the EU, the more requirements the UK has the less aligned it can be, so only those options further to the right in the graph remain viable.

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    The freedom of movement issue is not entirely correct; the Swiss have exceptions allowing them to impose quotas sem.admin.ch/sem/en/home/themen/fza_schweiz-eu-efta.html which led to a big fight with the EU. thelocal.ch/20181213/… Apr 21, 2019 at 22:02
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    @Fizz but it's free movement of people for citizens of most EU countries, right? The link in my answer only mentions quotas for Croatian, Romanian and Bulgarian citizens and only for a limited time period (which is almost over for Romania and Bulgaria and over for Croatia next July of year). Or is there some more recent development?
    – JJJ
    Apr 21, 2019 at 22:07
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    @Fizz interesting, perhaps more suitable for a different question. I think it's too nuanced to fully explain here. Also, I'm not sure how it's different from being an EU member. If you have no job as an EU citizen in another EU country they can send you back after a certain period as well. See here.
    – JJJ
    Apr 21, 2019 at 22:36
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    I can't understand this graphic at all. Apr 22, 2019 at 6:46
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    @immibis you start on the left. Being an EU member is the most aligned you can be with the EU. Underneath that there is a red line, if you don't want to be an EU member the next most aligned option is one step to the right. That also comes with red lines from the EU, the more requirements the UK has the less aligned it can be, so only those options further to the right in the graph remain viable.
    – JJJ
    Apr 22, 2019 at 6:57

Probably because the "Swiss model" is in flux. DW said

After four years of hard-fought negotiations, Switzerland has shrugged off a deadline for a treaty with the EU. It is concerned that freedom of movement requirements will flood the wealthy country with low-wage labor.

FT said

Swiss politicians resent what they regard as “blackmail” by Brussels [...]

The EU has granted the Swiss an extension of sorts to figure it out. That sounds somewhat familiar...

In the recent past, the Swiss were able impose some temporary immigration quotas on some EU countries (mostly newly admitted members); a few of these quotas are still in place. However it seems the new (draft) deal EU-Swiss doesn't allow for that. There's still some wiggle room in it for Swiss preemption for "at risk" jobs, itself a hard-fought issue in the negotiations. But this must look like a rather weaksauce solution in the UK given the hardline "take back control of our borders" stance.

DW suggested a mutual wait-game of the Swiss and the UK:

[T]he Commission [is] wary of going easy on the Swiss for fear of providing ammunition to Brexiteers. Meanwhile, many Swiss are happy to wait and see what sort of deal the British can extract for themselves out of the EU.

According to the FT article, in the new Swiss-EU deal there will be some role for ECJ e.g. with respect to state aid. An EU law blog explains how that can happen:

The [Swiss-EU] FA [draft Framework Agreement] rules on dispute settlement generally follow typical standards of state-to-state arbitration in public international law, with the exception of disputes where the interpretation of EU law is at stake. Notably, the chosen framework for dispute settlement is exclusive for both parties concerning interpretative disputes (Article 9).

To briefly sketch the procedure, if the relevant joint committee cannot find a solution to a dispute, after three months the EU or Switzerland can ask for the establishment of an arbitral tribunal. If the dispute raises a question of interpretation or application of one of the norms of the FA, the covered agreements or a referenced EU legal act (as provided for in Article 4 (2) FA), the arbitral tribunal turns to the CJEU [ECJ being the supreme instance of that], if the interpretation of that norm is relevant to resolve the dispute and necessary to enable the tribunal to take a decision (Article 10 (3) FA). The judgment of the [EU] Court binds the tribunal. [...]

The FA tribunal system is extremely closely bound to the CJEU, which in turn makes it politically very difficult to sell (in this case in Switzerland).

So the Barnier slide (which dates from a year before the draft EU-Swiss deal) is somewhat out of date. The new deal puts the Swiss in less clearly separate bucket from the rest of the EEA with respect to the "red lines" in that slide.

An article in the Economist written before the Swiss draft deal noted:

As far as Brussels is concerned, [...] Norway is treated as a friend—unlike Switzerland, which in place of the EEA has a laborious set of bilateral deals. The EU hates the Swiss set-up, because it is not dynamically updated to changed single-market rules and there is no agreed dispute-settlement mechanism. Diplomats in Brussels are clear that the Swiss model is not on offer to the British (many say it would not now be given to the Swiss).

And indeed the old Swiss model wasn't offered to the Swiss anymore (in the new draft framework deal).

In contrast the "Norway model" (EEA) appears more stable, so that's probably a reason why there is less reluctance to talk about it.

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