The Consequences of Brexit for the Customs Union and the Internal Market Acquis for Goods

15-06-2017

• The consequences of Brexit depend on the model which will be adopted for the future relationship between the EU and the UK. These models should be compared with a respect to a number of different parameters, which are not confined to substantive trade rules but include also questions of legal effect and dispute settlement. • There are very substantial differences between, on the one hand, the EU Membership and EEA models; and on the other the WTO/FTA models. Those differences are focused on the approach to regulatory convergence and to the legal effects of the agreements and their enforcement.

• The consequences of Brexit depend on the model which will be adopted for the future relationship between the EU and the UK. These models should be compared with a respect to a number of different parameters, which are not confined to substantive trade rules but include also questions of legal effect and dispute settlement. • There are very substantial differences between, on the one hand, the EU Membership and EEA models; and on the other the WTO/FTA models. Those differences are focused on the approach to regulatory convergence and to the legal effects of the agreements and their enforcement.