In the Scottish Government’s latest paper An independent Scotland in the EU, we learn that the SNP thinks that it would take between two to five years to join the EU. This is despite us learning that civil servants had previously warned that it could take up to eight years.
The truth is that no one knows how long it might take for an independent Scotland to join the EU, or indeed if it ever would. It would depend on political circumstances in the Scotland, the former UK and the EU, which are impossible to predict.
The UK in the 1960s fulfilled all of the criteria for joining the then EEC, but General de Gaulle famously said “Non”. He correctly predicted that the UK would not get on well in the EEC, and thought it would hinder the EEC’s goals.
Who can know which EU Government might object to Scotland joining the EU? Perhaps none would, but also perhaps there would be an EU Government that did not want to encourage secession in its own state.
But let’s say that the SNP is right and EU membership would happen quickly. This means that its proposal to use Sterling after independence would have to be of very short duration. The paper admits that Scotland would have to have its own currency to join the EU, so in order to be ready to join in less than five years it would have to begin immediately the process of setting up that currency. Alternatively, Scotland could wait to join the EU.
But again no one can possibly know when the economic conditions for Scotland setting up its own currency would be ready or indeed how long it would take. No advanced country has tried this. Would our Sterling mortgages be redenominated in Scottish pounds? Would our pensions be paid in Scottish pounds. But this would require negotiation. If you work for an English company based in Scotland how many Scottish pounds would you get per month after independence?
No one knows.
The SNP admits that there would be a hard border between England and Scotland. This has always been obvious. Scotland in the EU would have to apply EU regulations on the trade with non-EU former UK goods. It would also be necessary to convert currency. So, something I buy on UK Amazon now would cost a different price in Scottish pounds and would be subject to trade regulations that it presently avoids. I wonder if I would get it the next day.
Just as the Deposit Return Scheme might have involved companies outside of Scotland deciding it wasn’t worth selling their bottles and cans in Scottish supermarkets so companies might decide that it wasn’t worth selling their products in the small Scottish market as it involved too much paperwork.
The paper argues that Scotland would remain part of the Common Travel Area and that Scots would gain the same rights as Irish citizens to free movement both within the EU and within the former UK. This is perfectly possible. The former UK Government might well decide that cultivating good relations with Scotland was the best strategy just as it did when Ireland became independent. But this would not be up to the Scottish Government, it would be something that would have to be negotiated along with everything else.
The Scottish Government accepts that Scotland would have to join Schengen but thinks that it could obtain an opt out from having to check passports at the border between Gretna and Berwick. But membership of the Common Travel Area would be given only if the former UK electorate responded to Scottish independence with the good will necessary to offer free hospital treatment and benefits to Scots who had voted to leave the UK. It would be a political decision taken outside Scotland.
There would be passport free travel between Scotland and the rest of the EU, which means anyone who arrived in the EU could immediately fly to Scotland. Why use a dinghy to cross the Channel if you can fly to Glasgow and get a bus to London? This doesn’t happen with Ireland because it is not part of Schengen. It is this above all that allows Ireland to stay in the Common Travel Area. Perhaps the Scottish Government thinks it could have passport control between the continent and Scotland. But that would require not being part of Schengen at all.
Likewise promising to join the Euro while openly telling the Scottish electorate that you would never quite manage to do it, might lead to a modern General de Gaulle to say “Non, we’ve had enough of people treating the EU as a pick and choose menu. Either promise seriously to join everything or begone.” There is no use pointing to Poland. It joined the EU in 2004. Anyway, it is already a member. It’s Scotland that is the supplicant.
The SNP persists in its idea that the UK is a voluntary union of nations and that therefore Scotland was a member of the EU, taken out against its will, and that the process of rejoining would be easy because it was already a member. But this is historically illiterate, both about the UK and the EU. The UK is not a federation, nor is it a confederation, which leaves it being a unitary nation state which joined the EU as one country and left as one country. The UK was never a voluntary union, because it was never a union. It is the result of a union, which happens to call its parts countries. Scotland was never a member of the EU any more than Corsica or Catalonia are members now.
If Catalonia were to become independent from Spain it would have to join the EU from scratch, it would not be able to argue we were already a member. Well, what is the difference between Catalonia and Scotland? Hundreds of thousands of Spaniards have been on the streets objecting to the Spanish Government’s amnesty for Catalan separatists, what if some years from now they were on the streets objecting to Scotland’s membership of the EU because of the precedent it might set about Catalonia?
Even on a best-case scenario where the SNP got everything it wanted, Scottish independence in the EU would only attract you if you already supported it for other reasons. It’s clearly a worse situation than we have at present. Who wants a trade border with our biggest trade partner? Who wants to go through the uncertainty of a Scottish pound when we have no idea how much it might fall against Sterling. Who wants even the possibility of passport controls when driving to England?
If Scotland achieved independence, it would never join the EU. The conditions are too onerous. It would remain as closely aligned with the former UK as possible and would never make the steps necessary to join the EU. It is much more likely in fact that a future UK Government decides to reverse Brexit rather than either Scotland voting to leave the UK or voting to join the EU after that.
The excellent Effie Deans writes at Lily of St. Leonard’s here. To support her writing, payments are welcomed here.
This piece first appeared in Country Squire Magazine, and is reproduced by kind permission.
“But again no one can possibly know when the economic conditions for Scotland setting up its own currency would be ready or indeed how long it would take. No advanced country has tried this.”
What happened when Czechoslovakia split up?
The sooner they leave the UK the better.
I’m sure that had the whole country been able to vote in the 2014 referendum, they’d be long gone. Economically dependent on the English taxpayer, yet filled with loathing for us.
In today’s global political climate anything is possible. Anything which weakens UK will be welcomed in Brussels and the EU is nothing if not highly skilled at playing regulatory games to suit its purposes.