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Barnier drops big Efta hint: EU would accept Brexit legal pact that ‘dovetails’ with ECJ

In reply he cited the example of three EEA countries – Norway, Iceland and Liechtenstein – who have their own independent court in Luxembourg which oversees and upholds the rights of EU citizens living on their territory. 

The Frenchman said: “Never in that history of the EU have we ever had to discuss legal certainty for four million – or however many – citizens, 1.2 million UK citizens at least who live, work or are retired, who chose to live in one of the 27 EU member states. 

“Plus on the other side the three million odd of the 27 who live and contribute to the UK economy. We’ve never had such a situation before and we owe them this security, this protection. This is unique and extraordinary.

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