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What would UK-EU ‘Swiss-style’ relationship mean for Britons in bloc?

The topic has been raised this week though the UK government denied being interested. We look hypothetically at what such a move would mean

Switzerland’s relationship with the EU is made up of many treaties creating a kind of ‘light’ version of EU membership Pic: kavalenkava / Shutterstock

A ‘Swiss-style EU relationship’ has been in the news and social media discussions this week, with some suggesting that it could be suitable for the UK.

The Sunday Times reported that some UK government sources allegedly want such a relationship, while also believing the EU would concede it without the free movement of people being involved.

They allegedly, however, admitted that the EU would not offer this ‘upfront’ as it would be likely to see it as a case of ‘wanting to have one’s cake and eat it’.

The idea has, however, been denied by UK Prime Minister Rishi Sunak, as any form of ‘Swiss-style’ relationship would involve some level of the UK following EU rules, which Mr Sunak insists he does not want.

For example, Switzerland has agreements removing certain ‘technical barriers’ on trade, which require Switzerland being harmonised with EU rules on many kinds of product (eg. food), including rules around labelling, packaging or health and safety, so as to remove or minimise the need for checks and paperwork.

Read more: Claims that UK ministers seeking Swiss-style EU ties denied 

One benefit of a ‘Swiss-style’ relationship would therefore be easier cross-Channel trade.

Under another agreement, Switzerland also participates in the Erasmus educational and work placement programme, which many young Britons used to use to spend time in French or other EU universities.

However, when it comes to the real-life Swiss-EU relationship, the European Commission states that the country’s participation in the single market, including free movement of people, is also “a central pillar” and “part of the overall package”.

If the UK were ever to adopt this, there would be many benefits for ordinary Britons visiting or moving to France.

The Swiss relationship with the EU is, however, ‘slimmed down’ compared to full EU membership and the Swiss are not considered EU citizens. The relationship works via a complex network of bilateral treaties and replicates many, but not all, of the benefits and obligations of EU membership.

This means, for example, the Swiss in France cannot vote or stand in EU or municipal elections. Also, as Switzerland is not in the EU customs union, a ‘Swiss’ relationship would not remove all requirements for customs declarations and taxes.

Also, Switzerland does not benefit from the right for its driving licence holders to continue using their licences long-term after moving to France.

What would be the main benefits for British visitors to the EU?

A full ‘Swiss’ relationship would mean British visitors and residents would no longer be classed as ‘third country nationals’ by the EU, which would align them with many of the rules relating to the EU, as opposed to non-EU citizens.

Britons who live in the UK would therefore be able to visit France without passport stamping or having to give fingerprints and their photo as part of the European Entry/Exit System, set to come in in May 2023. They would also not have to obtain prior approval for their visit with an online Etias application and pay a €7 fee (this is set to start at the end of 2023).

Read more: Former ambassador warns of Entry/Exit System ‘chaos’ next year 

As a result, second-home owners would be able to come and go without being subject to the ‘90 days in any 180-day period’ rule, and could return, if they so wished, to a lifestyle of spending up to half the year in France. This is currently not possible without a temporary long-stay visa. 

Where there are separate lanes for EU and ‘other passports’, Swiss passports are considered equivalent to EU.

The UK would also be able to issue pet passports, as Switzerland is among the ‘Part one’ countries for pet travel, along with EEA states and European microstates such as Monaco. This would remove the need for pet owners or blind people with their guide dogs to pay for animal health certificates for each trip to the EU.

What would change for Britons living in France?

Not much would change for Britons who have Withdrawal Agreement (WA) cards because the Brexit WA allowed them to maintain essentially the same rights as EU citizens, though without the right to vote in municipal and EU elections. However, they would no longer be subject to an ongoing obligation to hold cards so as to have the right to live in France.

For other Britons, it would mean a return to pre-Brexit rules, meaning no requirement to apply for visas or residency cards to move to or study in France, and the freedom to do any kind of work, set up a business etc.

Technically, EU/EEA/Swiss citizens staying in France longer than three months are supposed to be able to support themselves, but France does not carry out systematic checks on this and requires no specific registration process or other paperwork.

Obtaining a visa as a third-country citizen involves an online application up to three months in advance of travel, at least one visit to take supporting papers to an office in London, Edinburgh or Manchester, and then, typically fees of £130 per person, plus a validation fee in France of €200 within the first three months. It is then necessary to apply for a residency card before the end of the first year, costing €225.

With a Swiss relationship UK state pensioners could come to France without a means test and would be able to live in France combining their pension with making a small side income from a self-employment job or trading on the internet, which is not permitted on a ‘visitor’ visa.

British retirees who have moved to France would have access to Aspa pension top-up benefit and those of working age could access RSA income support, without, respectively, having to show ten or five years of living in France on a permit allowing the right to work.

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