Another Model Post Brexit that has been discussed as been the “Norway” Model, this model basically refers to the European Free Trade Association (EFTA) based EEA agreement which was signed by Iceland, Lichtenstein and Norway.

Norway is also an affiliated member of Schengen – something the UK always chose not to be part of. Norway is part of the Single Market and therefore benefits from the free movement of goods, services and capital. However, Norway is not part of the Customs Union and therefore free movement of goods does not extend to goods from third countries.

Therefore although there is no duty to pay on goods whose origin status are of the EU, if goods are consigned from the EU but keep their third country origin status then duty is payable. Therefore again customs checks and declarations need to be implemented. The onus is also on Norwegian exporters to ensure they can prove their goods meet the preference rules of origin so that their customers in the EU do not have to pay duty. This can be very complex.

As Norway and the other EFTA Countries are not part of the Customs Union it can set its own Trade tariffs and free trade agreements. A list of those can be seen by clicking the link.

If this model was adopted post Brexit, assuming the UK would be successful in its application to join EFTA, it would not necessarily lead to frictionless trade.

Customs declaration would still need to be in place between the UK and EU27 and origin rules would be extremely important.

If you would like to speak to our Brexit Adviser, please contact or call 01522 846949 for more information.

Brexit BriefingCanada Free Trade Agreement