In thinking about Brexit, Canadians instinctively draw a parallel to Canada’s free trade arrangement with the United States and Mexico. President Trump’s threat to scrap NAFTA prompted anxiety in many potentially adversely affected sectors, and most Canadians sighed with relief when a compromise was reached – a compromise that Congress has admittedly yet to ratify.

The European Union (EU) entails many more constraints on national sovereignty than the new U.S.-Mexico-Canada agreement. The EU is a customs union that maintains common tariffs with nonmember states, and not merely an internal free trade area; the Schengen agreement guaranteeing free movement of EU citizens applies to virtually all EU members; the majority of EU countries agreed to a common currency; various decisions by Brussels constrain national human rights jurisprudence, employment regulations and so on. Ever since the U.K. joined in 1973, the majority of its leaders have been sceptical of the attempt by Eurofederalists to take the EU beyond a customs union and construct an “ever-closer union.” Britain is the only major country exempt from Schengen, and among the minority of countries that have preserved their own currencies.

From the U.K. perspective, the Brexit fiasco is an acute manifestation of the ambiguity about “ever closer union” prevalent among most EU citizens. Immigration from Africa and the Middle East during this decade has served as a catalyst for the evolution of “illiberal” democracies in eastern Europe, election of a populist anti-immigrant government in Italy and the rise of anti-immigrant populist parties in France, Germany, Sweden and other member countries. Unfortunately for the British, David Cameron forced U.K. citizens to vote on a simple in/out referendum question – and not continue with the pragmatic incrementalism at which the British are skilled.

Far from resolving U.K. ambivalence over EU membership, the 2016 Brexit referendum (52 per cent Leave, 48 per cent Remain) has exacerbated the Anywhere-versus-Somewhere divisions that pervade domestic politics in most EU states. At the time of writing (April 2019), U.K. polls suggest there is no U.K.-EU relation able to command a clear majority. Potential variants range from “crashing out” of the EU with no agreement to restoration of the prereferendum status quo.

Many advocates of a “soft Brexit” compromise, something between crashing out and the 2016 status quo, want a version of the “Norway model.” However, very few in the U.K. – and even fewer in Canada – have any solid knowledge of Norway’s status as a member of the European Economic Area (EEA) but not of the EU. John Erik Fossum’s article is an excellent introduction to the complex compromises required to make the Norway model work.

There are only five million Norwegians and, as Fossum describes, over time they have negotiated their way partially into the EU without actually becoming a full-fledged member. It is much more complicated for 66 million British to negotiate their way out. Is the “Norway model” an appropriate option for the U.K.? I am doubtful.

Click to read Adaptation Without Membership by John Erik Fossum.