Differentiation is now a common and normal phenomenon of European integration (and the UK has particularly benefited from it)
Indeed, differentiation is now considered a persistent feature of the European Union (EU). By 2010, more than half of EU policies were implemented in different ways across the EU.
Differentiation refers to variations in the scope of EU integration. It can be either internal when one member state does not participate in integration (such as the EMU) or external when one non-EU member state partakes in processes of integration (such as the European Economic Area).
During the 1970s, a report for the European Council on the future of European integration written by Leo Tindermands, the then Prime Minister of Belgium, first mentioned the notion of a “multi-speed Europe” whereby common objectives are pursued by a group of EU countries both able and willing to advance, it being implied that the others will follow later. During the 1990s, such differentiated integration became more and more institutionalized. Firstly, several opt-outs from the Maastricht Treaty were granted to the UK and Denmark in 1993. Secondly, the Treaty of Amsterdam in 1997 introduced the concept of enhanced co-operation, a procedure whereby a minimum of 9 EU countries are allowed to establish advanced integration or cooperation in an area within EU structures but without the other EU countries being involved. Thirdly, both the introduction of the third stage of EMU and the 2004 “big-bang” enlargement to 10 new countries led to an increase in differentiated integration and arguably to the emergence of a “two-speed Europe” (between the 19 euro area countries and the 9 other countries).
If the EU has become a system of differentiated integration, the UK has particularly benefited from it and became the “champion” of differentiated integration since it did not join the Schengen free-travel regime and secured an opt-out from the Euro, the Social Chapter of the Maastricht Treaty, the Charter of Fundamental rights as well as from parts of policies on Justice and Home Affairs. In 1990, writer and researcher Stephen George coined the famous phrase that Britain is an “awkward partner” in the EU since it came late to membership, had many problems adjusting to the method of governance in the Community which calls for compromises rather than ‘winner takes all’ strategies, and promotes both its “special relationship” with the US and its own global power rather than concentrating on its European neighbourhood.
Facing this “awkwardness”, the option of differentiated integration allowed European integration to move forward by overcoming the narrow preferences and veto power of the most status quo-oriented member states in a decision-making process which often requires unanimity.
Brexit as the only and isolated case of European disintegration
After the shockwave of the 2016 referendum outcome, the UK remains the first member state to engage in the process of disintegration.
Disintegration refers to the selective reduction of a state’s level and scope of integration. It can be either internal, when a member state remains in the EU but exits from specific policies, or external, when a member state exits from the EU.
Postfunctionalism, as a theory of European integration, emphasizes the potential of a clash between functional pressures and exclusive identity. This theory is particularly relevant for understanding the reasons behind both the differentiated integration of the UK within the European Union and the differentiated disintegration represented by Brexit. Indeed, this theory attributes differentiated integration and disintegration to a politicization process with several factors which can be applied to the United Kingdom:
1) The first factor is the depth of European integration in what were previously core state competences, such as managing immigration. The theory suggests that the increase in migration to the UK, first in the late 1990s following the setting up of the single market, and later in the mid-2000s following the Eastern enlargement, led the main political parties to abandon their liberal policies since in 2015, 63% of the British public named immigration as the most pressing issue.
2) The second factor is the exclusiveness of the national identity of the country, which, compared to other member states, is particularly noticeable in the UK: 60% of people in England describe themselves as English only.
3) The third factor is the rise of Eurosceptic parties, for example the anti-immigration, anti-EU far-right UK Independence Party (UKIP), taking the most votes and seats in the 2014 European Parliament elections, followed by the Brexit Party (led by the same leader Nigel Farage) in the 2019 EP elections.
4) The fourth is the use of referenda on EU issues, opening an institutional venue for demand for disintegration, for instance, the referendum initiated by the Hungarian government in 2016 in order to reject the EU’s migrant relocation plans. Applied to the UK, the June 2016 referendum would then be the last step of a process that begun well in advance, especially when in 2013 David Cameron announced a referendum on membership to counter his opponents inside the Conservative Party and the electoral threat of UKIP rather than discussing real issues in the United Kingdom’s European policy.
These postfunctionalist assumptions could be summarized as follows: Brexit might ultimately tell us more about the UK than about the state of European integration.
Ultimately, we can consider two main opposing visions for a post-Brexit Europe. The first one claims that Brexit will effectively trigger a process of European disintegration. The other one states that the exit of the EU’s most Eurosceptic partner might ultimately pave the way for a more integrated Europe without the blocking power of this country, just as differentiated integration allowed for this in the last decades. The remarkable unity of the 27 Member States on the Brexit issue over the last three years could be considered to provide support this second scenario.
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