Andy Burnham has reopened a debate that successive UK prime ministers tried to settle. But the history of Brexit suggests that getting closer to the European Union may prove just as difficult as leaving it.
For years, prime ministers have attempted to put Brexit behind them. Burnham has just done the opposite. By suggesting that Britain could “go all the way” and rejoin the EU, he has broken with the cautious approach of his predecessors.
His intervention has brought renewed urgency to the question: how close should Britain remain to the EU, and on what terms?
The options are not new. From Theresa May’s attempts to secure a bespoke deal to Boris Johnson’s hard Brexit, Rishi Sunak’s pragmatism and Keir Starmer’s reset, governments have grappled with essentially the same dilemma. That is, how can the country retain the benefits of cooperation with the EU without accepting the obligations that come with it?
May: trying to have it both ways
Theresa May entered Downing Street with the task of delivering Brexit but no blueprint for doing so. Her declaration that “Brexit means Brexit” concealed a fundamental contradiction: she promised to leave the single market and customs union, end free movement and end the jurisdiction of the European Court of Justice in Britain. But she also vowed to preserve close economic ties with the bloc.
May’s hopes for a bespoke deal clashed with the EU’s insistence that market access came with obligations. Her compromises satisfied neither hardline Brexit supporters nor pro-European MPs, ultimately bringing down her premiership. May’s experience exposed a dilemma that would haunt her successors. The closer Britain sought to remain to the EU, the harder it became to deliver the “control” promised by Brexit.
Johnson: getting Brexit done, but not settled
Boris Johnson offered a seemingly straightforward solution: stop searching for a compromise and embrace a more distant relationship. His promise to “get Brexit done” helped to secure a decisive election victory in 2019. Britain formally left the EU in January 2020, followed by an agreement that preserved tariff-free trade in qualifying goods but introduced new barriers such as customs checks and additional paperwork.
Yet withdrawal did not resolve the relationship. Trading frictions and disputes over Northern Ireland kept Brexit politically alive, exposing a paradox: delivering Brexit threatened to deprive its supporters of the very issue that had mobilised them. In other words, for politicians who had built their appeal around Brexit, declaring the job done risked losing a powerful means of rallying voters. The search for new Brexit victories therefore continued long after Britain had left.
Sunak: pragmatism without rapprochement
Rishi Sunak inherited a relationship marked by confrontation and mistrust. His approach was more pragmatic. The Windsor Framework of 2023 eased tensions that surrounded Northern Ireland’s post-Brexit trading arrangements, helping to restore trust between London and Brussels.
He also secured Britain’s association with Horizon Europe, an EU funding programme for research and innovation. These were significant practical achievements, but they did not amount to a fundamental rethink on Brexit. Sunak continued to champion the opportunities of regulatory independence while seeking to repair some of the disruption caused by withdrawal.
Starmer: the limits of the reset
Keir Starmer went further, promising to reset relations with the EU after years of confrontation from Conservative PMs. The Labour government pursued closer cooperation on security, trade and regulatory matters, but retained three crucial red lines: no return to the single market, no customs union and no freedom of movement.
This created a familiar problem. Britain wanted closer economic integration while continuing to reject some of the institutional arrangements that made it possible. The controversy surrounding a proposed youth mobility scheme underlined the political sensitivities involved in even limited steps towards closer ties. The reset offered opportunities for practical improvements, but its incremental approach could not eliminate the fundamental trade-offs of being outside the EU.
Burnham: a different route or the same dilemma?
Burnham now has two broad routes. The first is to deepen cooperation without pursuing full membership. A customs union could reduce barriers to goods trade, while participation in the single market through a Norway-style arrangement would offer much closer economic integration.
But these options come with conditions. Participation in the single market would require accepting EU rules and the free movement of people, without restoring Britain’s vote over those rules. A customs union would constrain independent trade policy and could require renegotiating trade deals signed since Brexit.
The second route is more ambitious: reopening the possibility of EU membership. Rejoining would restore British participation in EU decision-making, alongside the economic benefits of membership. But accession would require the agreement of all 27 member states, negotiations over Britain’s future obligations and some level of certainty that the next UK government wouldn’t just seek to come out again. The favourable terms the UK once enjoyed could not simply be assumed. Neither route offers a painless solution.
Burnham’s intervention nevertheless marks an important change. Where previous prime ministers largely sought to manage the consequences of Brexit while defending the settlement, he has questioned whether the settlement itself should be permanent. A decade after the referendum, British politics may be returning to its original EU dilemma.