Differentiated Integration in the European Union after Brexit

A UACES funded Collaborative Research Network


Why There Won’t Be a ‘Hard Brexit’Image result for stefan ganzle

Stefan Gänzle

Published on 29 July 2019

The new UK Prime Minister is settling into No. 10 Downing Street. Yet, contrary to the suggestions uttered by Boris Johnson and members of his Brexiteer government, it remains unlikely that there will be a ‘hard Brexit’. Various examples of disintegration in other regional organisations suggest that the United Kingdom (UK) will remain a close partner of the European Union (EU).

For more than three years Brexit has been an unavoidable topic dominating discourse in Europe. Although several options for future UK-EU relations have been explored in some depth – such as the Norway-model and, in particular, the set-up of the EU-Swiss bilateralism – there has hardly been any attempt to examine the European integration story or to look beyond Europe itself.

Comparable instances in the history of European integration

While the UK was already the most differentiated Member State in a number of policy areas, e.g. its non-participation in Schengen and the EMU, it is the first full-fledged Member State – and one of the leading ones in many respects – to leave the EU.

However, a number of comparable events exist: the departure of Algeria in 1962, Greenland in 1985 and the change of status in 2012 of the French island of St. Barthelemy located in the Caribbean Sea. Furthermore, disintegration (the withdrawal of a Member State) is nothing new in other regional organisations; for example, the case of Morocco for the Organisation of African States (OAU) or Mauretania for the Economic Community of West African States (ECOWAS). These examples have shown a complete rupture to be quite impossible.

Ever since its occupation of Algeria in 1830, France treated the coastal parts of the country as French departments – consequently, they became part of the European Community (EC) in 1957. Once the Franco-Algerian independence war had come to an end in 1962, Algeria separated not only from France but also from the EC. Yet, the new government in Algiers immediately sought to preserve a ‘special relationship with Brussels.

In fact, these privileged economic relations remained informally in force before fading out in the 1970s (with disastrous effects for the Algerian economy). It was only in the early 2000s that Algeria managed to negotiate a new partnership deal as part of the EU’s European Neighhbourhood Policy.

The aim of achieving national sovereignty was a consequence of Algeria’s ambition to depart from both France and the EC. In the case of Greenland, it was the very motive. Greenland had no intention of leaving Denmark when it submitted, via Copenhagen, its note of resignation of EC membership. It aspired for more autonomy from EC regulations and governance in order to formulate its own economic policy, in particular with regards to fisheries. Still, close relations with the EC/EU were established right after departure and developed to such an extent that today there are discussions of completely separating from Denmark and further reinforcing relations with the EU.

The fact that disintegration does not automatically imply a complete rupture is well documented in the example of St. Barthelemy. The island’s status vis-à-vis the EU had been formally ‘reduced’ to an overseas territory in order to be able to conduct its own economic policy. Being relatively affluent, the island preferred less regulation while being able to afford fewer EU subsidies.

Examples from outside the EU

Let us be clear: the difference in scope and depth of European integration compared to other regional organisations is quite remarkable – it is not ‘integration snobbery’ (a term coined by Philomena Murray in 2010) to acknowledge this. Still, these comparisons hold a couple of lessons. When Morocco left the OAU in 1981 over protests that Africa’s top-level diplomatic organisation had not formally acknowledged Morocco’s (to date) contested supremacy over Western Sahara, it quickly lost its influence vis-à-vis continental Africa. In 2017, it eventually decided to re-join what is now the OAU successor, the African Union.

While in the case of Morocco political considerations had prevailed, Mauretania’s leaving the ECOWAS in 2000 was primarily sponsored by trade concerns which the country hoped to direct more towards its Mediterranean partners. As these hopes did not materialize, Mauritania has recently started a process of reintegration into ECOWAS.

‘Hard Brexit’ or hardly Brexit? What do these cases mean for Brexit?

Despite the differences between these individual cases, together they make a ‘hard Brexit’ hardly conceivable. We should instead understand this as Europe’s first instance of ‘differentiated disintegration’ (Schimmelfennig 2018, Leruth et al. 2019). That is, once the dust of negotiation tactics has settled, it is safe to assume that forms of a differentiated and graded relations will prevail. Even if there will be a no-deal Brexit in the short term – as suggested by Johnson – in the long-run differentiation rather than disintegration will come to the fore.

This means that in the run-up to October 31, EU Member States should explore both avenues for anticipating the shape of future relations with the UK while at the same time preserving unity among Member States. The upcoming months will be a rollercoaster, but comparative and historical regionalism has already indicated the final destination.

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