Model | Access to Single Market? |
Regulatory Restrictions? |
Free Movement of People? |
EU Legislation? | Impact on Your Business? |
European Economic Area Agreement e.g., Norway |
Yes — Free movement of goods, services and capital. |
Harmonized product standards and service regulations. |
Yes — Free movement of people would continue. |
U.K. would still be required to adopt much EU law. |
|
Multiple Bilateral Accords e.g., Switzerland |
Only in specific sectors covered by bilateral agreements. |
U.K. would need to comply with EU regulatory requirements for exports to EU. |
Yes — Likely U.K. would still have to sign up to free movement of people. |
The U.K. would need "equivalent" laws to EU in areas such as consumer protection, competition law and environmental law. |
|
Customs Union e.g., Turkey |
Yes for goods but not for services. Would have to impose the EU common tariff. |
U.K. would need to comply with EU regulatory requirements for exports to EU. |
No — U.K. could set own immigration policy. |
The U.K. would need to harmonize laws in areas such as competition, intellectual property and consumer protection. |
|
Free Trade Agreement (FTA) e.g., Singapore, Canada, South Korea |
Potential access to whole or part of single market, depending on the agreement. FTAs are usually designed for free trade in products rather than services. |
U.K. would need to comply with EU regulatory requirements for exports to EU. |
No — U.K. could set own immigration policy. |
No requirements to follow EU legislation. |
|
World Trade Organization e.g., Current situation between EU and USA |
No — U.K. exports to EU would be subject to the EU's common external tariff. |
U.K. would need to comply with EU regulatory requirements for exports to EU. |
No — U.K. could set own immigration policy. |
No requirements to follow EU legislation. |
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