Schengen is not part of the EEA agreement. However, the four EFTA states participate in Schengen and Dublin through bilateral agreements. They apply all the provisions of the acquis in question. There are some precedents for EFTA countries that have limited exemptions. The EEA agreement allowed Liechtenstein to limit for a certain period of time the number of residence permits it issued to other EEA citizens. The contract was then extended by five years. There is a significant difference in size between the population of Liechtenstein with about 38,000, that of the United Kingdom with about 60 million. There are also other important differences from the agreement between Britain and the EU. Finally, and not least, the EEA-EFTA agreement does not contain the same broad dispute settlement agreements for independent arbitration proceedings. www.barrons.com/news/uk-seals-temporary-brexit-trade-deal-with-efta-nations-01603361123 Article 56.3 of EFTA stipulates that a new EFTA Member State “requests membership of free trade agreements between Member States on the one hand and third countries, state associations or international organisations, on the other.” As a member of a customs union, a country that joins EFTA has not been able to fulfil this obligation. EFTA membership does not exclude the establishment of a customs agreement with the EU; existing EFTA countries regulate their relations with the EU through different instruments. This government and the last government have always insisted that they simply want a free trade agreement based on the Canadian model.
Nevertheless, British negotiators have sought all possible privileges and benefits that go beyond a simple free trade agreement. The search for supplements such as mutual recognition of qualifications and rules is only an attempt to preserve the benefits of the internal market that we have helped to shape, but which we have now insisted on leaving the country. Gove is the minister responsible for planning the non-deal, and he now urges Boris to reach an agreement, for fear of “double shame” on the economy, if the UK returns to WTO rules for its trade with Europe and the rest of the world during a pandemic. The Brexiteer Gove looked over the cliff and rushed. Even if textual differences play a role and the InstA is interpreted only on the basis of its text, circumstances should be taken into account. They would make a clear case for a situation that corresponds to the situation in the case of Ukraine.