By Steven Martin Kensington

Britain – The world is watching as Britain’s process of leaving the European Union continues on. An observer may wonder what will happen, how they will deal with the situation and how they will end up. Brexit was only a close victory, and it is not everyone who are satisfied. Yet some of them decides to deal with the situation as it is and works to get a soft Brexit which is sustainable for the British economy. The Welsh First Minister Carwyn Jones, for instance, holds this position, and suggests that they should follow the Norwegian model of relationship with the European Union1. So, what is the Norwegian model, and how could it fit in a British context?

As Professor Lazowski boldly claims, there is no such Norwegian model2. It refers to the relation Norway has with the European Economic Area (EEA) and European Free Trade Area (EFTA). Norway is one of four members comprising the latter. Participation in the EEA is optional for EFTA members, but is compulsory for those that are EU-members. Norway, along with Iceland and Lichtenstein, are called “EEA-EFTA states,” and this is what is referred to when the “Norwegian model” is mentioned. Lazowski calls the EEA “a very complex, heavily institutionalized and rather expensive alternative to EU membership.” An article on the website of the Norwegian government explains EEA as a treaty meant to ensure free flow of the “four freedoms,” goods, people, services and capital between its nation members3.

A little history lesson of Norway’s relation with the Union might make things a little bit clearer. Polls since 2003 have shown that the people of Norway are generally a bit sceptical to the EU4. The highest result against Union membership was held in August 2012, where a stunning 74.5% of the population rejected it5. There have been two official votes of whether Norway should join the Union, one in 1972 and one in 1994. The people voted no both times but won with a lower margin in the latter. Neither of these were anywhere close the result gotten in the poll from August 2012, and in both cases was victory only 2-3.5% over a tie. If the vote was held again in the autumn of 2012, perhaps it would have had such a result.

We have now seen clearly the Norwegian Euro-Scepticism, but now we are left with the question: Why, or how, then, did Norway get into such a relation with the Union? The short answer is that rich countries, such as Norway and Switzerland, who didn’t want to join it, had to find a way to trade internally with the EU members within the continent without becoming it themselves. As the European Commission, and eventually the European Union, became an increasingly powerful international political body in the years following its creation, so it couldn’t be expected that one could avoid trading with its member states. The government of Norway concluded in October 1992 – and taken into effect in 1994 – with a majority of ¾ that the nation should become a member in the EEA6. According to a brochure published by the Norwegian government in 1993, has the main reason for joining the cooperation agreement been that “the member states can achieve more by taking decisions together rather than on their own.” In current Prime Minister Erna Solberg’s words, “to strengthen trade and economic ties with the EU – and, some would say, to prepare the ground for EU membership.7” She also says that the EEA agreement became a political compromise as proponents of joining the Union saw it as standing in the way for full membership, whereas those against EU disliked it for transferring power to Brussel. Agreement in disagreement, you could say, but it was surely the second option which was far less divisive than the question of full membership or none.

There are, of course, downsides to this option, which Mr. Lazowski describes. One of the most important ones is that neither Norway, Lichtenstein or Iceland can sit by the negotiation table in the Council of EU, although they have to follow all different kinds of directives and laws therefrom through the EEA. Another point is that switching from being an EEA-EU state to a EEA-EFTA would cut the United Kingdom from the Common Agricultural Policy, which has benefited British farmers by direct subsidies in over 40 years. He claims that it is “an illusion” to believe that the United Kingdom would gain sovereignty by leaving the EU and swapping for the EEA-EFTA. “Instead, it would go from being a law-maker to a law-taker.” If his presumptions are correct, the “Norwegian model” therefore becomes a flawed one to build on for the UK. David Cameron agrees, saying “while they pay, they don’t have a say.8

Are there any good case in support for Britain building on the Norwegian model? Ambrose Evans-Pritchard, International Business Editor for the Daily Telegraph, made such a case last summer in his article Leave camp must accept that Norway model is the only safe way to exit EU. He responds to Cameron’s view with that Norway does indeed have a say in the EU. They can de facto veto over EU laws under Article 102 of the EEA agreement, and their net payment of £106 a head in 2014 is “trivial” according to Evans-Pritchard. He also claims that Norway doesn’t even need to implement “all EU law as often claimed.” Here he refers to a report by the Norwegian government, which shows that it has adopted “just” 1,329 of the 7,720 EU regulations in force, and 1,369 of 1,965 EU directives. “The elegance of the EEA option,” Evans-Pritchard opines, “is that Britain would retain access to the EU customs union while being able to forge free trade deals with any other country over time.”

If it is such a good solution to Britain, why does both its Prime Minister and its EU minister advocate against them adopting the model? Erna Solberg stated her opinion on this on the website of the London School of Economics and Political Science in 2013. First, she mentions the difference in population size between the countries. Norway is a small country with merely five million people, whereas the UK has over 63 million, in addition to it being an international power reaching far wider than Norway. Second, 75% of exports from Norway go to the European Union, whereas the UK has good trade relationships with the rest of the world, though also a large chunk of that is indeed with the EU. “We simply have different comparative advantages and priorities vis-á-vis the EU,” she says. Mrs. Solberg states her support for the nation staying in the Union (reminder: this was written in 2013), but this question does not go within our topic of discussion.

The Norwegian EU minister Berger Rosland agrees, though for other reasons9. She states that there is a difference in attitude between Norway and Britain towards the European Union, in that Norway has the four freedoms – transport of goods, people, services and capital – whereas the Leave-campaigners are against the free movement of people, i.e. immigration. She therefore thinks that it is contradictory, if one holds these beliefs, that Leave-campaigners would agree on becoming an EEA-EFTA state. If we look back to Evans-Pritchard’s article, we can now see why he supports Britain following the Norwegian model. He is a strong advocate of these four freedoms, including movement of people.

It seems apparent now that division between the following question is the fundamental one in determining whether one supports Britain becoming an EEA-EFTA state: Is EU-controlled immigration good for Britain? Of course, the other pros and cons are also of huge importance, but this seems to me to be the major one. Immigration is one of the most controversial issue in Europe, and it shouldn’t be difficult to find merit in that the standpoint in question is, at least by many people, rooted in this issue. The complicated issue is now simplified, but one should take not of Adam Lazowski’s writings on the issue for a better understanding of it. There are many more objective factors he mentioned, as already mentioned, which determines whether one supports it or not. Conclusively, the position on this matter is largely a matter of values, not merely of objective pros and cons. Therefore it can be difficult in finding agreement here, but we shall all see where Britain may end up when the time comes, whether the result be good or not.


[1] Kentish, B. (2018) Corbyn will pledge to keep UK in customs union, Welsh First Minister says.

[2] Lazowski, A. (2016) Norwegian model for the UK: oh really?



[5] Ntb (2012) Høyrevelgere deler ikke partiets syn på EU.

[6] Regjeringens informasjonsutvalg for Europasaker (1993), 55 minutter om Norge og EF

[7] Solberg, E. (2013) The ‘Norwegian model’ would be a poor alternative to EU membership for the UK.

[8] Evans-Pritchard, A. (2016) Leave camp must accept that Norway model is the only safe way to exit EU.

[9] Bosotti, A. (2018) Remainer hopes DESTROYED as Norwegian EU minister says Norway-option NOT good fit for UK.