Could the UK really return to the EU?

Commentary

Britain’s new prime minister has said that Brexit was a mistake and Britain should have a much closer relationship with the European Union. Ros Taylor looks at what that relationship could look like, and asks whether there is a chance the UK will rejoin the EU or the single market.

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UK Prime Minister Andy Burnham at the Labour Party Conference, on 29 September 2026.

They were the words many Labour supporters had been longing to hear. 

"Brexit has done more harm than good," Andy Burnham told the 2026 Labour party conference. Later this year, he would lay out to Britons "what I believe the different options are for Britain’s long-term relationship with our European partners. I will see if we can find consensus around one."

Yes, a decade after Britain narrowly voted to leave the EU –  and whether that meant the single market and customs union too was entirely unclear in 2016 – Britain is coming back. Maybe. If we can agree on what we want, and if the EU lets us.

The French president Emmanuel Macron welcomed the move, but warned that if the UK rejoined it would have to compromise. "You cannot choose between the freedoms of the Union and you cannot decide to take what suits you and not the rest. So come back."

Britain can, however, try to sign up to some aspects of the EU without actually rejoining. This approach has plenty of downsides, which is why Brexiteers rejected it after the referendum, but it represents the kind of compromise that might be able to persuade a majority of Britons.

No one seriously pretends that Brexit has not damaged Britain’s economy. The question is how much independence the country is prepared to sacrifice in order to revive the trade and benefits it lost.

The status quo

The Labour government is already trying to negotiate a better relationship with the EU than Boris Johnson’s Trade and Cooperation Agreement offers, though progress has been ponderous. In exchange for ‘dynamic alignment’ on plant and animal health regulations, carbon pricing and electricity, and limited freedom of movement for young people, the UK would get smoother access in these areas.

Rejoining a customs union

This would mean that the UK could no longer set its own tariffs on imports and would have to abandon the ones it has negotiated since 2020. Like Turkey, it would have to agree a bespoke arrangement with the EU. It would cut a lot of paperwork, especially in manufacturing. But whether it boosted growth much would depend on the scope of the deal, which in turn would depend on the degree of regulatory alignment and the EU’s demands.

Rejoining the single market

Known as the ‘Norway’ or ‘Swiss’ option, this would return the UK to the single market, but means paying into the EU budget (Margaret Thatcher famously negotiated a rebate, which the UK would be unlikely to repeat) and accepting freedom of movement. 

Andy Burnham’s rhetoric on immigration has been confusing. In his conference speech, he said immigration control had been "weakened by Brexit". He was probably talking about the fact that Brexit means the UK can no longer return people who arrive on small boats to France. This is correct, but glosses over the practical and diplomatic difficulties of doing so. Alternatively, Burnham may have been implying that losing access to EU workers, who can move about freely without the need for visas, had forced the UK to recruit people from Asia and Africa instead. This is also true. But the desire to have more control over immigration was a main reason for the Brexit vote.

Burnham would need to convince sceptics that, because Central European countries are richer than they were in the 2000s, freedom of movement would not lead to another wave of new arrivals from the EU. He could point to the fact that only Britain, Sweden and Ireland chose not to impose restrictions on those workers, which is why so many came. And he is right to imply that Brexit has not ‘solved’ tensions over immigration, even if it has given Britain more control over legal migration. It is now Britons’ top concern.

But the EU could decide – as Macron hinted – that if Britain wants to rejoin the single market, it will have to go the whole way and sign up to the EU again. Simon Usherwood, a professor of politics at the Open University, thinks the EU would probably block the Norway option. 

"Negotiations would involve a lot of UK asking for exemptions and EU pushing back, partly because classic cherry-picking line, and partly because of precedents for other European Economic Area [EEA] states," he says. Meanwhile, Norway and Switzerland may oppose it because the EEA is "designed for small, less-politicised countries".

On the other hand, since the UK would have to accept EU rules without having any say in making them, we would no longer be able to try to veto the bloc – as we did in 2011 – or elect pro-Brexit MEPs like Nigel Farage who sought to disrupt it from within. The EU might appreciate that.

‘Full-fat’ rejoin

This has the advantage of clarity. It would give Britain full voting rights and is the obvious riposte to the question: "What’s the point of just rejoining the single market, when it means signing up to EU rules and getting no say?" Polling suggests that a pledge to rejoin the EU would win back voters whom Burnham needs, especially in Scotland and Wales.

"Half-baked calls to enter a customs union or join the single market won’t bring the transformational economic heft to avoid further drift and decline, or the political payoff to prevent Nigel Farage’s Reform UK gaining power," says Naomi Smith, the chief executive of the pro-rejoin pressure group Best for Britain. "The choice Burnham must face is whether to go big – or go nowhere at all."

But Burnham also knows that pro-Brexit parties are currently polling at 45 percent of the vote. And public support for rejoin fluctuates depending on what people perceive it to involve. If it means joining the euro, support falls. It will be hard to convince the public that the pound is safe if membership depends on committing to the single currency.

Then comes the question of whether Brussels will have enough confidence in Britain to start a rejoin process. Since all the right-wing parties are opposed to it, the UK can hardly be relied upon in the medium to long term. The irony is that the EU has also changed since Britain left. Far-right, often Eurosceptical, parties are on the rise. The single market will probably endure, but would the Labour party want to rejoin a bloc where France, Germany and Spain might all have far-right leaders?

The thought of another referendum is also unwelcome. It is difficult to argue that since Britain held a referendum on whether to join (in 1975) and leave (in 2016), it could rejoin without holding another one. Few of us will relish the culture wars it would probably stoke. Arguably, the amount of time Westminster spent on Brexit left some serious domestic problems to fester.

Among some Britons, too, there is a degree of stubbornness allied with an element of the sunk cost fallacy: we made our bed, so we might as well lie in it.

Burnham’s speech was the first piece of good news pro-rejoiners had had for a decade. No wonder they are excited. But they are going to need an awful lot of stamina.

 

The views and opinions in this article do not necessarily reflect those of the Heinrich-Böll-Stiftung European Union | Global Dialogue.