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BREXIT

Could this EU Green Card save freedom of movement for Britons in Europe?

Imagine a card that would let Brits in Europe keep freedom of movement and all the rights of EU citizenship after Brexit. It might sound like fantasy but one organisation is leading the way to make it happen. We spoke to the campaign's founder.

Could this EU Green Card save freedom of movement for Britons in Europe?
Alex Stubb, former PM of Finland (centre), Madeleina Kay, EU SuperGirl and Roger Casale (left) in the European Parliament in July 2018 for the launch of the prototype Green Card. Photo: New Europeans.

A campaign by New Europeans is lobbying the EU to intervene in Brexit and issue a card that would offer “privileged status” for UK nationals currently living in the EU, as well as for Europeans settled in the UK and essentially allow them to keep their treasured freedom of movement.

The campaign is being led by Roger Casale, a former Labour MP who now lives near Florence in Italy and who heads the New Europeans.

“The Green Card would ring-fence the rights that you had as an EU citizen,” Casale told The Local. “It would create equivalent status.”

With nearly 55,000 signatures and counting, a petition on change.org started by Casale is slowly gathering steam.

An EU-issued “Green Card” could be a vital addition for the 3.6 million or so EU nationals living in the UK, as well as the 1.2 million or more Brits in Europe. 

Under his plan the EU Commission would issue a resolution to offer the 'five million', UK nationals living in the EU and EU citizens living in the UK, the right to a special recognition for having acquired residency before Brexit.

This would effectively guarantee a sort of privileged status, far greater than the rights agreed under the current Withdrawal Agreement, for five million UK and EU citizens whose rights are set to be stripped back by Brexit. 

A Green Card would enable British citizens who have already exercised their treaty rights before the Brexit to retain free movement, a right that will be lost if Theresa May's Withdrawal Agreement is ratified.

It would help restore a sense of “status” and “privilege” that EU citizenship entailed, Casale said.

It would also help EU citizens in the UK prove that they have settled status swiftly and efficiently to obtain the services, employment and housing benefits that settled status affords.

As Casale notes, the Home Office has said it will not offer EU citizens any additional document to prove settled status – everything will be digital. This will make it difficult for EU citizens to prove they have the additional rights guaranteed by the settled status package at any given time. 

Casale's idea has already been applauded by the Financial Times and New Europeans is the 2019 recipient of the Schwarzkopf Award. Casale's organisation was also the recipient of the CiDAN/ESDA Europe award in late 2018,  “in recognition of New Europeans' leading role in the campaign to safeguard the rights of EU27 citizens in the UK and Britons in Europe following the Brexit referendum.”

Casale himself has also received a Medal of the President of the French Republic. But it is the response from key EU institutions that will matter most. 

“It's at a critical stage,” said Casale, a former Labour MP for the London constituency of Wimbledon.

“The Green Card works regardless of if there's a deal or no deal,” adds Casale, a British citizen, who has settled near Florence in Italy. “The rights afforded it by such a scheme would be for life.”

Casale is due to give evidence at the Constitutional Affairs Committee of the EU parliament (AFCO) in early 2019.

How does he hope a Green Card could come about and what kind of time frame can we expect?

If AFCO makes a proposal, the EU parliament would then vote on it. Should the European Parliament approve the idea, the EU Commission would then have to pass a resolution for the EU Council to vote on. The minimum timeline would be 12-18 months in a best case scenario, Casale admits. 

New Europeans hopes the platforms it has created for citizens rights in the EU, such as Friendship Group on Citizens' Rights, the 20-MEP strong cross-party group at European Parliament, will help raise the campaign's profile.

“It was always my view that there would be a problem to rely on the Withdrawal Agreement. The risk of not getting what you want was always too great” says Casale, explaining how New Europeans and citizens' grassroots campaign group British in Europe ultimately pursued different strategies and objectives in pursuit of similar goals. 

“Somebody needed to have a Plan B,” says Casale, whose organisation's focus is on lobbying the EU institutions to help resolve the impasse on citizenship rights, rather than lobbying Brexit negotiators directly, an approach preferred by British in Europe and the3million, which represents EU citizens in the UK.

“We didn't feel that it was right to go into the negotiations,” adds Casale. 

British in Europe and New Europeans continued to work together and in parallel, from one group attending the other's mass lobby on parliament in February 2017, to giving evidence to the same European Parliament committees. 

One of the appeals behind the Green Card campaign is that it is is cross-party and endorsed by voters on both sides of the Brexit divide, argues Casale. “A lot of Leave voters think EU citizens' rights should have been sorted two years ago,” he says. 

The EU has the experience to implement such a system – a Blue Card, a “work permit issued to highly-qualified non-EU citizens” is already in place.

“They already have the set up and the machinery. They only need to change the ink from blue to green,” quips Casale.  

The former MP with extensive networks among MEPs is confident there is broad support for the motion in the European Parliament. Whether that can translate into getting Brits in he EU free movement will depend on how the EU chooses to react.

That could depend on whether the UK continues to remain on course for a potential exit without a deal from the EU. Such a scenario would see UK nationals living in Europe at the mercy of legislation of individual Member States (France and Germany have already passed contingency laws), as there would be no Withdrawal Agreement or pan-European motion to protect them. 

A Green Card would be one option to fill that void. 

READ MORE: Quiz: How well do you know Brexit?

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TRAVEL NEWS

Passports: What are the post-Brexit rules for dual-nationals travelling in Europe?

People who have more than one citizenship often hold multiple passports, so what does this mean for crossing borders? Here's what you should know.

Passports: What are the post-Brexit rules for dual-nationals travelling in Europe?

For many readers of The Local, gaining citizenship of the country where they live helps them to feel more settled – but there are also travel benefits, including avoiding the long ‘non EU’ queue when coming back into the Schengen zone.

But this week the problems associated with travelling while holding dual citizenship came to light, leaving many people wondering what they should know when they are entering different countries.

Put simply – which passport should you use? And do you have to carry both with you?

Financial Times journalist Chris Giles tweeted that the UK Border Force “detained” his dual-national daughter while she was travelling from France into the UK with her German passport – and not her British one. 

He went on to say that UK border guards released his daughter. According to Giles, the border staff said she should have had both passports with her “and asked why she was travelling on her German one”.

The rules on dual-nationality have not changed, but now that the UK is not in the EU, there are strict rules on non-Brits who enter the country (and vice-versa) which has made it trickier for travel.

For instance, UK nationals receive a stamp in their passport when entering Schengen member states because they are only allowed to stay up to 90 days within an 180 period (unless they have a visa or residency card).

READ ALSO: Brexit: EU asks border police not to stamp passports of British residents 

People coming from the EU to the UK can generally visit as a tourist for up to six months without a visa – but are not allowed to carry out any work while there.

So which passport should you show?

The first thing to be aware of is there are no specific rules on travelling with more than one passport. 

Travellers can choose to use whichever passport they prefer when going to a country. 

But one thing to note is that it’s worth using the passport that is best suited to your destination when travelling there. Each country has its own set of immigration and visa rules that you’ll need to research closely.

It could be that one passport is better suited for your trip – and you may be able to avoid visa requirements.  

READ ALSO: How powerful is the German passport?

In the case of the UK, many people are still getting to grips with the different rules that apply because it’s not in the EU anymore.

A question submitted to the Secretary of State for the Home Department in September 2021 provided some insight into this issue. 

The question from Labour’s Paul Blomfield asked what steps the UK government “is taking to enable dual UK and EU citizens to travel to the UK on an EU member state passport without having to further prove their UK citizenship?”

The Conservatives Kevin Foster said: “Border Force Officers examine all arriving passengers to establish whether they are British citizens, whether they require leave to enter or if they are exempt from immigration control.

“Where the passenger claims to be British, but does not hold any evidence of British citizenship, the officer will conduct all relevant checks to satisfy themselves the passenger is British.

Border control at Hamburg airport.

Border control at Hamburg airport. Photo: picture alliance/dpa | Christian Charisius

“When dual nationals who are eligible to use e-gates travel to the UK, they will enter via the e-gates without being examined by an immigration officer.

“We recommend all dual nationals, including EU citizens, travel on their British passport or with evidence or their British citizenship to minimise any potential delay at the border or when commencing their journey.”

The Local contacted the UK Home Office to ask if there was any official advice. 

A spokesman said: “An individual can present whichever passport they desire to enter the UK, however they will be subject to the entry requirements associated with the nationality of the passport they present.”

They said anyone who is looking for more information should check out guidance on entering the UK and on dual nationality.

In short, if you present a German passport on entry to the UK you will be treated the same as any other German citizen – which can include being quizzed about your reasons for visiting the UK – as border guards have no way of knowing that you are a dual-national. 

Do I have to carry both passports?

There’s no rule requiring you to have both passports, but you won’t get the benefits of a British passport (entry into the UK without questions) if you don’t show it.

Likewise if you are a French-British dual national and you enter France on your UK passport, you will need to use the non-EU queue and may have your passport stamped.

Should I think about anything else?

An important thing to remember is that if you apply for a visa and register your passport details, the same passport has to be used to enter the country. 

It could also make sense to travel with both passports, just in case. 

However, note that some countries – like the US – require that US nationals use a US passport to enter and leave the States even if they are dual nationals. 

In general, it’s best to use the same passport you entered a country with to depart.

The rules and systems are different depending on the country. But many countries require people to show their passport when leaving – and they will either stamp or scan the passport – this is how authorities know that a foreign visitor hasn’t overstayed their time in the country. 

So if your passport is checked as you leave the UK, you should show the one you arrived with, just to ensure there is a record of you arriving and leaving.

However as you enter France/Germany/other EU destination, you can show your EU passport in order to maximise the travel benefits of freedom of movement.

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