– The first, known as the positive approach, where commitments are made only for those sectors listed in the schedule of commitments, such as in GATS or the EU-South Korea FTA;
– The second, or negative approach, entails a broader liberalisation, as commitments apply a priori to all sectors unless explicitly mentioned in reservations. This approach was used in CETA, where reservations were introduced in two different types of annexes. Annex 1 of CETA contains those rules that violate the commitments under the agreement that parties want to maintain, subject to a ratchet clause (i.e. if those restrictions are lifted in the future they cannot be reintroduced). Annex 2 of CETA instead allows restrictions not subject to a ratchet clause, i.e. restrictions that can also be introduced in the future. The European Council guidelines on the framework for future relations do not specify which approach will be used for services; CETA may be taken as a basic model and the more liberal negative approach may be used at least with respect to cross-border services and investment. Even if CETA is used as basic model that does not mean that reservations will be similar. The number and scope of reservations may vary from FTA to FTA. Moreover, within an FTA, the number of reservations may vary greatly from Member State to Member State (see figure 10), as in some Member States, services are more liberalised than in others. Reservations may also vary according to the sectors in terms of number, type (Annex 1 or 2), and scope.