Brexit border headache: what can other EU frontiers teach Britain and Ireland?

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Drive south along Croatia’s Adriatic freeways and you will stumble on the kind of border headache that Ireland might face when Britain leaves the EU.

An hour-long tailback at the border with Bosnia and Herzegovina makes motorists fume. A desultory passport check and everyone is on their way again – but not for long. Ten miles further south there’s another border, this time crossing from Bosnia back into Croatia.

When Croatia joined the EU in 2013, these became hard borders again overnight. If Britain opts for a “‘hard Brexit”, ending freedom of movement with the EU and requiring new trade arrangements, the same issues could rear up along the 310-mile (500km) frontier between Northern Ireland and the Irish Republic.

Officials on both sides seem determined that no hard border will re-emerge. Many feel that passport checks in particular would be unnecessary, however urgently the British feel they need to “take back control” of their borders.

But questions remain: how will customs enforce differences in tariffs without searching lorries on the scores of roads that run between north and south? If the border is not policed, how will EU nationals who migrate to the Irish Republic be prevented from moving to the north, and then to Great Britain?

Like the Irish divide, the 850-mile demarcation line in the Balkans cuts across cultural, family, and business ties, with bilateral trade worth £1.1bn (€1.3bn).

When Croatia joined the EU on 1 July 2013, the bloc’s external frontier was redrawn along the country’s borders with Serbia, Bosnia and Herzegovina, and Montenegro. The border with Bosnia and Herzegovina has proved particularly troublesome. Both were once republics of Yugoslavia, and 15% of Bosnian citizens are ethnic Croats, most of whom have Croatian EU passports.

In some cases, the results are surreal: houses and farms that are part in the EU and part not, and farmers who need to show ID to get to and from their own fields.

Ivan Glavota runs a winery with a 100-year-old wine cellar in Imotski, a picturesque small town on the Croatian side that is perched on cliffs above a striking azure lake. He has 1,000 vines on the Bosnian side of the border. In addition to the occasional bureaucratic hassle of crossing to his own land, he is not able to obtain EU or Croatian funding for the grapes harvested across the border, though the wine is made in Croatia.

“This creates a problem for numerous small agriculture producers in the area,” he says.

The border has become synonymous with such frustrations. Even though most Bosnian goods enjoy free-trade status within the EU, Bosnian agricultural goods can only be exported to Croatia through two customs posts on their long frontier, pushing up costs. Tariff-free trade privileges were suspended temporarily earlier this year during a bureaucratic wrangle.

“People tend to sometimes forget that Croatia is now part of a different system, that things are not like they used to be,” says Amer Kapetanovic, assistant minister for bilateral affairs and economic diplomacy at the Bosnian foreign ministry. “All these bureaucratic nuances suddenly became very important and this is the moment of realisation that Croatia is in the EU and we are not, despite the fact that we used to live together in one state, we speak the same language, listen to the same music, have the same jokes, have family either side of the border.”

Kapetanovic warns his counterparts to avoid a clean break when it comes to Brexit negotiations.

“It would be wise if during the negotiations on article 50 both the UK and Ireland strongly opt for continuing with an open border policy,” he says. “As neither are part of Schengen [passport-free travel zone], I think it would be the wisest approach. Otherwise some of our examples affecting our daily life with our EU neighbour Croatia might appear in your situation as well, and I’m sure your people would not like it.”

Croatian former interior minister Ranko Ostojic, who was in office when Croatia joined the EU, points out that citizens living within 30km of the border are eligible for special passes. But he acknowledges that there are long queues at the border as all other non-EU citizens (including most Bosnians) are subject to “full passport control” at the border, and require biometric passports.

The Nordic model

About 2,000 miles to the north, another EU border provides further insights into what happens when two close trading partners have a hard tariff border.

In the Swedish town of Charlottenberg, sweet shops are thriving because of the different prices of sugar in Sweden and Norway.

Every weekend, Norwegians come to fill their boots – literally – from an assortment of 4,000 varieties of cheap candy in stores such as Gottebiten, which is almost the size of a football field.

Enormous Swedish shopping centres within driving distance of Oslo also cater to Norwegian demand for low-tax tobacco and alcohol.

The creation of the Nordic Council after the second world war saw passport-free travel and a common labour market implemented across the Nordic countries. Sweden’s accession to the EU in 1995 did not change the arrangement, and indeed Norway’s membership of the European Economic Area makes issues such as freedom of movement moot.

The two countries that once split apart have grown closer together, despite one being inside the EU and the other outside. So could Norway and Sweden hold any lessons for the future of Britain and Ireland?

“Passport-free movement while Norway is not an EU member is quite unique,” says Peter Dafteryd, a councillor for the ruling centre-right group on the town council of Strömstad, another community near the border with Norway. “The problem in Ireland is that that kind of arrangement has not been prepared. It will be a struggle for both sides, I think.”

The EU’s Interreg programme spends as much as €20m a year on strengthening economic cooperation across the border. “The EU wants to have good relations with its neighbours,” says Michael von Essen, a project officer for Interreg on the Swedish side.

Some Norwegian companies like to establish themselves inside the EU, so they open small offices in places such as Strömstad, just 80 miles from Oslo, according to Dafterydl.

“That way they have a daughter company in the EU, with quite different taxes and regulations. It’s a way of getting into the EU without being a member,” Dafteryd says. Norwegians bring more than 8bn krona (£715m) into the Strömstad area every year, paying the salaries of some 2,000 Swedes, he adds.


Another model for the future of the British-Irish border may be glimpsed where Germany meets Switzerland.

Officially, there have been no land border controls between the two countries since 12 December 2008, and journeys by air have been denoted “inland flights” since 29 March 2009 – which means people only need to show their ID card to board a flight from Berlin to Zurich, and can walk from Basel to Weil am Rhein without any documents.

Apart from the odd cow fence, there are no fortifications along the 362-km border. About 54,000 people who live inGermany commute daily to Switzerland.

But since Switzerland is not part of the EU’s customs union, both countries carry out some checks at the crossings. For example, even though Switzerland is part of Schengen, Germans on holiday to the Swiss Alps are not allowed to take more than two bottles of wine or 500g of beef. Likewise, if expensive skiing equipment is purchased in Verbier, it must be declared to German customs when crossing back into the EU.

The line between controlling traffic of people and goods is hard to draw. Swiss customs officials are also required to carry out ID checks for security issues, and not just at fixed border points but also via mobile units that operate along the border. Customs officials say they can carry out spot checks without creating tailbacks at border points.

In September 2010 Bavarian police gained the first lead that eventually resulted in the discovery of the Munich art hoard after customs officers discovered €9,000 in cash on collector Cornelius Gurlitt during a spot check on a Zurich-Munich train. The legal limit is €10,000.

Since the start of 2015, even couriers who travel two miles to deliver pizzas from an Italian restaurant in Weil am Rhein to Basel have to declare their stone-oven-baked wares with Swiss customs. It’s easy to see why: a pizza margherita, which sells for about €4.90 on the German side of the border, costs €13 in Basel.

It is no coincidence the term “shopping tourist” was voted the Swiss word of the year in 2015. People in German border cities such as Konstanz complain about Swiss visitors gridlocking their medieval city.

Shopping tourists are already emerging in northern Ireland, as the slump in sterling makes goods in Britain that much cheaper.

But there have been no reports of gridlock in Belfast as yet.