Brexit Jargon: from Article 16 to the WTO

Joe Griffin
Joe Griffin

Brexit is a story of paradoxes; the referendum was nearly half a decade ago, and yet it’s only come into effect now, making it both an old story and ongoing concern. 

Additionally, it can be hard to find one’s bearings because so many issues were on and off the table over this time, and many of the consequences of Brexit are only being felt now (with more developments likely to emerge). 

On top of this, there’s the jargon. Several new expressions have entered the lexicon since 2015 (the year prior to the referendum itself). Here are some of the most commonly used phrases and what they mean, relevant to businesses, accountants and bookkeepers either side of the Irish Sea and beyond.  Some phrases will raise their heads in coming months, while others (like the first one) were in the news in recent days.

Article 16 

This one hit the news in recent weeks, when it became the focal point of a disagreement between the UK and the EU over the procurement of covid vaccines. 

Article 16 is part of the EU’s Northern Ireland protocol, essentially allowing Northern Ireland access to the European free market. (Northern Ireland shares a border with the Republic of Ireland; the former is part of the UK, the latter is not.)

The intention of this protocol is to allow free movement across the border of this politically sensitive region. 

However, Article 16 can be invoked if either side (the EU or UK) claims that the situation causes “economic, societal or environmental difficulties”. This was briefly triggered in a row over access to AstraZeneca vaccine, but the EU has since reversed its decision. 


A phrase especially familiar to Irish businesses and Northern Irish residents, essentially it means a soft border between The Republic of Ireland and Northern Ireland. The former, not being part of the UK, remained in the EU after Brexit, but Northern Ireland (being part of the UK) is now no longer a member of the EU.  

Brexiter / Brexiteer 

One who was/is in favour of Brexit. 

Common Market / Single Market 

The “market” of the EU that allows the “four freedoms” between member states; free movement of goods, people, capital, and services.

The UK, upon leaving the EU, is no longer guaranteed these freedoms. 

Customs / Customs Union / Customs Partnership 

A customs union (or partnership) is an agreement between two or more nations on customs. At present, EU member countries can trade across international borders mostly without tariffs.

So where does this leave the UK? Well, per the EU’s own guide: “For the purposes of customs, the UK is treated as any other non-EU country as of 1 January 2021. In particular, customs procedures and formalities now apply to trade between the UK and the EU.

“However, in accordance with the agreed Protocol on Ireland and Northern Ireland, EU customs rules and procedures generally continue to apply to goods entering and leaving Northern Ireland.”

Divorce Bill 

The sum owed to the EU by the UK upon leaving, to settle the UK’s financial obligations as it leaves. It’s estimated to be around £7billion. 

European Economic Area (EEA) / European Free Trade Association (EFTA)

European Economic Area (EEA) refers to countries that are not members of the EU but that are members of the European Free Trade Association.

European Free Trade Association (EFTA) countries are; Iceland, Norway, Switzerland and Liechtenstein. They have access to the European single market but are not part of the Customs Union.

European Commission

An EU branch of governance that looks after its everyday business, including enforcing legislation. 

Free trade agreement (FTA)

An agreement between countries to make trade easier, often by keeping tariffs low. 


Someone who is in favour of the UK staying in the EU. Some have campaigned for a second referendum - either choosing again whether to stay in the EU or on specific Brexit terms. A second referendum seems unlikely at time of writing. 

Schengen Area

A collection of countries, including both the EU and additional countries, with free movement (i.e., few or no passport or border controls). 

The four countries in the Schengen Area that are not members of the EU are: Iceland, Norway, Switzerland, and Liechtenstein. There are also microstates; Monaco, Vatican City, and San Marino.

Single Market 

Despite the fact that the EU consists of 27 member states, there is a mostly shared currency, and relatively free movement of goods, people, capital, and services throughout the EU. Therefore, it is seen not as separate markets, but in this context, as a single market.

Swimming Pool Brexit

This refers to Northern Ireland, which despite being in the UK, has some different rules to other UK countries - much like a swimming pool has different rules in its shallow end and deep end. 

United Kingdom

This is legally defined within the Brexit withdrawal agreement to encompass the United Kingdom and Gibraltar, the Channel Islands, the Isle of Man, and the Sovereign Base Areas of Akrotiri and Dhekelia in Cyprus.

Withdrawal Agreement

The agreement upon which the UK left the EU. It is publically available and, should you want to, you can access it via the EU’s official website

World Trade Organisation (WTO)

The global trade body with several member nations and trading blocs around the world, including the US, the UK, China and the EU. 

The EU has trade agreements with several countries that were drawn up over years. Now that the UK is no longer in the EU, it may have to create new agreements with these countries (such as the US). 

For member countries that don’t have a free trade agreement, they can negotiate tariffs, quotas and other concerns at the WTO, which is based in Geneva.  

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