 However, Jersey did not appear on the list of European States and Territories outside the Union and the Communities prepared by the European Council and the Commission.This is a result of the manner of implementation of the Treaty arrangements under the Act of Accession in 1972.Jersey would have been fully within the European Communities like Gibraltar, being a European territory for whose external relations the United Kingdom was responsible, but that was limited to the Protocol 3 arrangements under article 355 TFEU to reflect the then existing relationship with the United Kingdom.