How to keep the border on the island of Ireland open has proven to be a difficult one to solve in the Brexit talks so far. Both the UK and the EU want to avoid a return of a hard border posts but a workable solution to avoiding physical infrastructure or checks has not been agreed.

The EU already operates customs borders with countries outside of the EU and these models have been discussed as possible options to solve the Irish problem. We now look at how a border operates between Turkey and Bulgaria, Norway and Sweden and France and Switzerland to get a sense of what the reality might look like for Northern Ireland and Ireland after Brexit.

Norway/Sweden border

Sweden is in the EU, Norway is not. But Norway is a member of the European Economic Area (EEA) which means that is part of the EU’s Single Market. This means that Norway enjoys free movement of goods (i.e. no tariffs), capital, people and services but there are still customs checks at the border.

The border between Norway and Sweden is over 1,600 kilometres long and there are 10 official border crossing points for customs purposes. Lorries go through customs once generally. At the main border in Svinesund, on average, 1,300 heavy goods vehicles pass through the border every day. Technology is used at the border which means that lorries only generally stop once and customs officials in both countries work together.

According to a report by the BBC, the average wait time from when a lorry arrives at the border to when it clears customs is 20 minutes.

Switzerland/France border

France is in the EU, Switzerland is not. But Switzerland is part of the Single Market but is not in a customs union with the EU. This means that Switzerland’s regulations in terms of product quality and standards are fully aligned with EU rules; thereby reducing quality control checks at the border.

The border between Switzerland and France is over 500 kilometres long and there are customs controls in the form of physical infrastructure at several points along the border. Some are only open at certain times (i.e. Monday to Friday) to receive declarations and others are no longer manned.

The average wait time for a lorry carrying goods is reported to range from 20 minutes to 2 hours.

Turkey/Bulgaria border

Bulgaria is in the EU, Turkey is not. Turkey is in a customs union with the EU which means that certain goods can cross from Turkey to the EU and vice versa without customs duties arising. Turkey is not in the Single Market so there is no free movement of services, people or capital. There are also restrictions on several types of goods including agricultural products.

Because Turkey is not in the Single Market, several regulations and EU standards need to be adhered to and checked before goods are allowed into the EU. Therefore there is a need for traders to have certain documentation ready at the border including export licences, invoices and transport permits.

The border is around 270 kilometres long and there are three designated crossing points for customs purposes. Coupling this with the fact that additional documentation is required, this means that long delays at the border between Turkey and Bulgaria is normal. There are reports of waits ranging from 3 hours to in excess of 24 hours in order to clear customs.