Thomas Verellen, Utrecht University
March 25, 2025
Facing pressure from a US president who suggests Canada become the 51st US State, Canada looks to Europe for new alliances. Historical ties and shared democratic values make Europe a natural partner. However, joining the EU is not possible, even if closer bilateral cooperation is possible and desirable. To strengthen its economic resilience and, ultimately, its sovereignty, Canada should restructure its economy and infrastructure to facilitate east-west trade rather than relying primarily on north-south routes.
Against the backdrop of repeated US threats of annexation, suggestions that Canada join the European Union keep popping up. A recent poll even indicated that 44 percent of Canadian respondents believe their country should join the EU, while only 34 percent oppose the idea. For years, I have humorously suggested this at my Canadian in-laws' Christmas dinner table. In the run-up to Brexit, I suggested tongue-in-cheek that Canada could perhaps replace the UK. Under the second Trump administration, the joke suddenly seems to be taken seriously by academics and think tankers, including e.g. Frédéric Mérand and Tommaso Pavone.
Canada cannot join the EU
While acknowledging the sentiment, it is necessary to emphasize, as other EU lawyers such as Steve Peers and Steven Blockmans, and a European Commission spokesperson, have done, that Canada cannot become a member state of the EU. The Treaties restrict EU membership to ‘European States,’ a term interpreted geographically to include states on the European continent. Granted, Europe's geographic borders are sometimes ambiguous (for example, the Caucasus region). There are also transcontinental countries such as Russia and Türkiye.
Yet some countries are clearly not located in Europe, such as Canada. In 1987, Morocco applied to join the (then) European Communities (the precursor to the European Union) by sending a letter to French President Mitterand, whose country held the presidency of the Council at that time. Morocco’s application was rejected because it did not meet the requirement of being a ‘European state’ as outlined in the Treaty of Rome.
The letter sent to the Moroccan King Hassan II was very diplomatic, emphasizing the desire of the (then) EEC to build stronger ties with Morocco. No reference is made in the letter to Morrocco’s geographic location. However, in the Council’s internal debates, the Council Presidency did mention that it had conveyed the message to the Moroccan foreign minister that EEC membership was open only to European states (see the screenshot. The full texts are available here).
Mérand and Pavvone argue that ‘Europeanness’ is more cultural and political than geographic. They point to the EU’s overseas territories such as Greenland or Saint Pierre and Miquelon, to dismiss the geographic reading of ‘Europeanness’. However, these territories are legacies of empire. They had been incorporated by their colonizing powers before the Treaty of Rome was enacted. When their European colonizers joined the EU, they brought their colonies along, attempting to 'Europeanize' their empire. (This included racial segregation systems, as described by Hanna Eklund in her important work on colonialism in the Treaty of Rome.) Equally importantly, however, as overseas territories of EU Member States, they are part of states that are in fact geographically located in Europe. As such, the relevant parallel would not be Canada, but Türkiye, whose territory spans both Europe and Asia, and which has been considered to qualify as a ‘European state’ in the meaning of the Treaty.
Ireland, like the UK for that matter, is part of the European continent, despite Pavvone's passing comment to the contrary. A more challenging case may actually be Cyprus. However, geographical factors were also significant in that context. In its 1993 opinion on Cyprus' application for membership of the EU, the European Commission considered that not only its culture, but also its geographical position, confirmed its vocation to belong to the (then) Community. While Canada may very well be the ‘most European of non-European countries, as Prime Minister Carney put it during his recent trip to Europe, no such argument based on geography can be constructed for Canada.
Finally, and it is worth emphasizing the point: the EU would rightfully face criticism for civilizational double standards if it rejects Morocco for not being 'European' enough while welcoming Canada.
Options for deepening ties with the EU
In the unlikely event that Canada were to send a letter to Mr. Costa of the European Council to apply for EU membership, it would receive a polite letter explaining that membership is not an option but deepening the relationship is. As the Moroccan precedent shows, Canada should not expect sending such a letter would lead to a better deal, as suggested by Mérand and Pavvone. The willingness to work together is already there on both sides of the Atlantic; a letter will not strengthen Canada’s hand in any way.
How can closer integration be achieved? But more importantly, should Canada even seek closer ties with the EU? What would be the benefits, and what would be the costs?
As Frédéric Mérand has laid out in the policy paper mentioned earlier, there are different models. During the Brexit negotiations, then EU chief negotiator Michel Barnier summarized the options in a graphic:
The graphic does not fully capture the complexities of the relationship between each of the models. For example, Ukraine has committed to adopting much of the EU’s rulebook through the association agreement it concluded with the EU, but it does have an independent trade policy, whereas Turkey has more regulatory autonomy but has joined the EU in a customs union, which limits its ability to conduct its own trade policy.
The graphic does give a sense, however, of what it would cost for Canada to move closer to the EU without the option of EU membership on the table. Norway, Iceland and Liechtenstein are for all intents and purposes part of the EU’s internal market. They are, however, rule-takers, not rule-makers as they are not represented in the EU’s decision-making bodies. To keep access to the internal market, they automatically follow EU rules.
This is different from the Swiss model: the EU-Switzerland relationship is governed by several bilateral agreements, requiring Switzerland to mirror EU laws. All of these agreements are connected, in the sense that if Switzerland terminates one agreement, all other agreements would be terminated too, thus cutting Switzerland out of the internal market. (This is the so-called “guillotine clause”.) The Swiss-EU bilateral relationship significantly limits Switzerland's regulatory autonomy, often leading to conflicts between Bern and Brussels.
Integration with the European Union along the Norwegian, Swiss or even Turkish lines thus comes with a cost: Canada would become a rule-taker and would thus lose some of the sovereignty it is currently fighting hard to protect. Moreover, for a country that is far less economically integrated with the EU internal market, and likely to remain so by virtue of its geography (the type of integrated supply chains that exist between Ontario and Michigan are difficult to replicate between Quebec and France), such a position is bound to create tensions.
Greater resilience does not run through EU membership
As a long-time observer of Canada, my sense is that strengthening Canada’s economic resilience, and ultimately its sovereignty, will need to run primarily through internal action, by Canada’s federal government, to develop Canada’s internal market, and to make it easier for Canadian businesses to trade with partners other than the United States.
CETA, the trade agreement that Canada has signed with the EU, and which has been provisionally applied since 2017, offers opportunities for deeper trade ties. Already today, Canada and the EU can trade quasi-tariff-free. Yet to deepen EU-Canada trade in practice, Canada needs to build the infrastructure needed to get its exports to EU markets. East-west trade corridors have remained underdeveloped as Canada has gone all-in on trade with its southern border. Developing this infrastructure has been on the agenda for decades, as anxieties about excessive reliance on the United States are not new. Yet provincial opposition has stood in the way of concrete action. (Just a couple of days ago, Bloc Québecois leader Blanchet reaffirmed his opposition to a pipeline connecting Alberta to Nova Scotia.)
To be clear, further integration with the EU can be pursued, for example in the field of services. The CETA agreement offers possibilities to negotiate and conclude mini-deals to mutually recognize qualifications. One agreement has been reached on the mutual recognition of the professional qualifications of architects. More such agreements can be negotiated. They can be adopted through a simplified procedure.
There are no magic bullets for Canada to get out of its current predicament of excessive reliance on its unreliable southern neighbour. However, Canada has the resources to become more resilient, by reducing internal trade barriers and diversifying external trade. The CETA agreement can contribute to this effort, but ultimately, it is up to Canada to take the necessary actions to fundamentally restructure its economy.
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