International Journal of Sociology and Social Policy

Civil society as a contested field of meanings

Sandrine Roginsky, Sally Shortall,
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Civil society as a contested Civil society as a

contested field of
field of meanings meanings
Sandrine Roginsky
CELSA-PARIS IV Sorbonne, Paris, France, and
Sally Shortall 473
School of Sociology, Social Policy and Social Work, Queens University
Belfast, Belfast, UK
Abstract
Purpose – During recent years, the concept of civil society, particularly global civil society, has come
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to the fore in both academia and policy circles. A key component of recent theoretical and policy
research is the attempt to do international comparative research on the meaning of civil society. The
purpose of this paper is to argue that the language and the terminology used to describe the agents of
civil society are reflective of cultural and historical contexts of societies, have distinct meanings and
cannot be used interchangeably.
Design/methodology/approach – In different national contexts, the key agents of civil society are
referred to differently; nonprofit sector, voluntary and community sector, third sector and social
economy. In comparative studies, scholars often list these concepts to indicate that they recognise
that the agents of civil society are referred to differently in different societies. The article offers a
socio-historical analysis of each concept. It is concluded that teasing out the differences, as well as
the similarities, between the nonprofit sector, voluntary and community sector, third sector and social
economy, is crucial to robust comparative research on civil society.
Findings – This paper exposes a number of limitations of each of the terminologies used to describe
civil society. They all present a much more limiting notion of civil society than that proposed by the
founding fathers. None seem to capture the range of civil associations in any society. Yet,
assumptions are made that the terminologies used have similar meanings rather than attempting to
clarify and define exactly what is being written or described. This is exacerbated by the
interchangeable usage of nonprofit/third sector/community and voluntary sector/social economy. In
order to progress beyond culturally specific understandings of civil society, it is necessary to
examine the terminology used and how it emanates from a specific cultural and political context.
Having a clear understanding of the language used and what it signifies is crucial to robust cross-
national comparative research.
Originality/value – This paper examines context specific understandings of civil society and the
terminology used to define it; a question not previously addressed. It is hoped that this article will
generate much needed further debate on cross-national meanings of civil society.
Keywords Citizenship, Citizen participation, National cultures, Society, Language
Paper type Research paper

Introduction
Sociology is by definition comparative, as its mission is to identify social patterns, or
social phenomena that are held in some way to be typical. Where sociological
analysis states that it is comparative, it usually refers to the study of social patterns
across nation-states (Smelser, 1976). The theoretical, methodological, and analytical
difficulties posed by cross-national research were recognised by early sociologists,
notably Durkheim and Weber, and contemporary sociologists continue to grapple with
developing robust comparative research. Definition lies at the heart of all social International Journal of Sociology
analysis. Without an agreed set of concepts to give some order to reality, there is no and Social Policy Vol. 29 Nos.
9/10, 2009 pp. 473-487
way to group perceptions and begin making sense of them. Definitions and
classifications are crucial to clear thinking and careful analysis. Such definitional # Emerald Group Publishing Limited
0144-333X
development and improvement in the basic ‘‘technology of thinking’’ is an absolute DOI 10.1108/01443330910986261
 IJSSP prerequisite to even the most rudimentary understanding (Salamon and Anheier,
29,9/10 1997). This is particularly true in cross-national settings, where common language
and common cultural understandings are not available to help structure perceptions.
The central objective of this article is to contribute to the development of robust
cross-national comparison of civil society by demonstrating the differences between
the often used interchangeably theoretical concepts: nonprofit sector, third sector,
voluntary and community sector and social economy. Each concept refers to agents
474 in civil society in a particular national context. However, the terms are not synonyms.
Civil society is not a new concept and it was first coined by Adam Ferguson (1767).
The concept evolved in tandem with the nation-state and the market (Bartelson, 2006).
While the concept of civil society remains contested after 240 years, it is generally seen
as distinctive from the political state and the economic market. Following on from
Ferguson and de Tocqueville, civil society is seen as voluntaristic ‘‘associationalism’’,
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where people’s relations are driven by democratic discourse, solidarity, civility, honesty,
and mutual respect (Alexander, 2006; Morris, 2007). Ferguson understood civil society to
upholding moral values with the advent of commercial interests (Kettler, 2005), and
similarly Oakeshott (1990) describes ‘‘civil’’ association or civitas as ‘‘moral
association’’. It is distinct from the state and the market. Yet this distinction is no longer
so clear. Anheier (2002) argues that the growth in civil society is due to the significant
amount of public funds made available to nonprofit, voluntary and community, and third
sector organisations, all agents of civil society. He further argues that the migration of
civil society into commerce should not be of too much concern (p. 2). This is a debate for
another day. Of concern to us in this article is that this universal pattern of government
funding of civil society organisations has led to the presumption of a global civil society
which shares common characteristics cross-nationally. While this is the case to some
extent, it remains that the terminology used in different national and cultural contexts
have different meanings. It has long been recognised that cross-national comparative
research needs to engage an interpretative approach, being mindful of linguistic and
cultural factors, together with differences in research traditions and administrative
structures (Hantrais, 1995). This is what we are advocating for the study of civil society.

By looking at the usage of the third/voluntary/nonprofit/social economy sectors as

expressions of civil society the aim is twofold. First, is to explore the implicit meanings
hidden in the particular usages; second, to challenge the perceived ‘‘fixity’’ and
universality of the idea implicit in each meaning. Examining the figure of speech makes it
possible to analyse the usage of each term as a contextual process of interpretation, with
transformative effects on the social domain it is defining. Wittgenstein observes that the
usage of words gives meaning to the intuition; in other words that the speaking of
language is part of an activity, or a form of life (Wittgenstein, 1997, p. 11). Each way of
‘‘speaking civil society’’ reflects then a way of distinct life and relations particular to that
life. It means that the understanding of civil society is distinctly located at a particular
juncture of the usage or performance of civil society. This article provides a theoretical
and analytical introduction to the culturally specific concepts used to describe civil
society. It is laid out as follows: it offers a deconstruction of each of the concepts;
nonprofit sector, third sector, community and voluntary sector and social economy.
Through this analysis, it highlights differences between American and European
thought[1]. It presents the differences in the cultural and theoretical traditions each
concept represents. It highlights that the concepts reflect national, historical and cultural
contexts, and concludes that attempts to study a
 global civil society must be mindful of the cultural differences between the concepts Civil society as a
of third/voluntary/nonprofit/social economy sectors, and the inaccuracies of using contested field of
these terms interchangeably.
meanings
Nonprofit sector and the American influence
‘‘Nonprofit sector’’ is a concept that first emerged in the USA, although it now holds
international currency, reflecting American dominance in civil society research. This 475
is linked to the international profile of The Johns Hopkins Center for Civil Society
Studies, one of the best funded and longest established centres for civil society
studies. Its funding sources are international, enhancing its global presence, and
explaining the wide adoption of nonprofit as a synonym for civil society.
The nonprofit sector is defined as ‘‘groups of organisations that qualify for tax
exemption and for tax-deductible donations’’ ( James, 1990, p. 21). In the nonprofit
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sector, organisations are not allowed to distribute their profits to their owners or staff.
DiMaggio and Anheier gave a more specific determination:
. . . nonprofit organizations are those falling under section 501(c)3 of the Internal Revenue
Code (a category including most nonprofit hospitals, cultural organizations, traditional
charities, foundations, schools, day-care centres and foundations, among others), or the
smaller, related 501(c)4 category (civic leagues and social welfare organizations, which are
denied tax-deductible contributions but which may engage in some political or commercial
activities from which (c)3s are barred); these do not include such mutual-benefit
associations as labor unions, workers or consumers cooperatives, veterans organizations, or
political parties, which the law treats separately (DiMaggio and Anheier, 1990, p. 138).

A similar definition was formulated by Salamon and Anheier (1993). According to the
authors, the nonprofit sector includes all entities that are formal organisations having
an institutionalised character; constitutionally independent of the state and self-
governing; nonprofit-distributing; and involving some degree of volunteerism
(Salamon and Anheier, 1993, p. 537).
The comparative nonprofit sector project directed by Salamon and Anheier made a
major contribution towards the development of a common definition for civil society.
This definition dominates international discussions. The Johns Hopkins Comparative
Nonprofit Sector Project ( JHCNSP) was launched in 1990 among 12 countries[2] to
inquire ‘‘into the scope, structure, history, legal position and role of the nonprofit
sector in a broad cross-section of nations’’ (Salamon and Anheier, 1997, p. xi). In
order to facilitate comparative analysis, the first task of the project was ‘‘to formulate
a common language and concept of the ‘nonprofit’ sector’’ (Salamon and Anheier,
1997, p. 4). The JHCNSP represents a comprehensive attempt by contemporary social
scientists to define civil society as occupying a distinctive social space outside of both
the market and the State (Salamon and Anheier, 1997, p. 1). If the State (public) is the
first sector, the market (private) the second, the nonprofit is the third sector or civil
society. The project developed a ‘‘structural-operational’’ definition of the nonprofit
sector. Five key structural and operational characteristics define the range of entities
most commonly associated with the nonprofit sector. To be included in the sector, an
entity has to be: organised or formal (i.e. institutionalised to some extent), private (i.e.
institutionally separate from government), nonprofit distributing (i.e. distinguished
from the market), self-governing/independent (i.e. not controlled by an outside force
such as the state), voluntary (i.e. involving some meaningful degree of voluntary
participation). While this is the definition for the nonprofit sector, it is worth noting
 IJSSP that the term nonprofit sector is used interchangeably with the third sector, the
voluntary sector, and even civil society.
29,9/10
The JHCNSP also created a methodology for the international comparison of the
nonprofit sector, stressing economic aspects. The focus is on three themes:
employment and volunteering, expenditures, and financing. The data collected by the
Project are useful in broadly identifying the considerable scale and significance of the
sector. However, it is narrow and culturally specific in focus, overlooking much of
476 what, for instance, in the European Union (EU) is understood to be the third sector
and civil society. It is to these limitations that we now turn.
Historical data have been used to demonstrate the contextual specificity of the
definition of the nonprofit sector and indicate some of the weaknesses inherent in
attempting to test theories of the sector with data compiled using the structural-operational
definition (Morris, 2000). While the definition proposed by Salamon and Anheier aims to
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be internationally useful and relevant, other scholars argue that the definition is neither
universal, nor accurate in its theoretical inclusions and exclusions (Evers and Laville,
2004). The John Hopkins definition is based on the criterion of non-redistribution,
underlying the American configuration of the sector, along with a significant role for
foundations. This criterion does not take into account the specific legal requirements of
European countries for which the distinguishing criterion is the existence of limits on
redistribution (Laville et al., 1999). Indeed, in the criterion of nonprofit distribution lie the
widest diversities between the American and European thinking. In Europe the main
criterion is not whether the profits are distributed to owners or not but whether the general
purpose of an organisation is to work on a commercial basis or not.
The distinctive feature of the European approach is the attention given to the
historical dynamic perspective (Laville et al., 1999). The American approach,
manifested in the Johns Hopkins Project, focuses on defining the main national
components of a sector comprising a community of ‘‘nonprofit organisations’’. In
contrast, the European approach, while not discarding the synthetic dimension, takes a
more analytical perspective, focusing on generating voluntary association typologies
that stress different modes of action and the changes in them over time.
Above and beyond this original research hypothesis, the European definition is broader
because the exclusion by Johns Hopkins of co-operatives and mutual aid societies on the
grounds that they can distribute some of their profits to members cannot be justified in a
European context (Laville et al., 1999).

The third sector concept is a broader one in Europe, and the organisations involved
are seen as part of the ‘‘social economy’’ rather than the nonprofit sector (Defourny
and Develtere, 1999).
Dissimilar though they may be, the European experiences nevertheless have one thing in
common: they represent a tradition that is different from the American tradition, an attempt
to establish ‘‘reform economies’’ including not only forms of charity and voluntary service
but also collective action based on mutual aid and the participation of socially committed
citizens (Laville et al., 1999).

European research has tended to concentrate on the themes of the welfare State and the
rights of citizens. To paraphrase what Taylor notes about the attitude of voluntary
organisations, scholars ‘‘consider the individual not only as a consumer but as a citizen’’
(Taylor, 1992, p. 162). In the European approach, choices between sectors have not been
primarily market choices but rather they have been political (Muukkonen,
 2000). Such a perspective automatically introduces various concepts such as charity Civil society as a
organisations, social movements, and the social economy.
contested field of
The American definition of the nonprofit sector reflects core cultural components
of American culture. The American creed includes equality as one of its basic values, meanings
but this is understood as equality of opportunity rather than outcome. At the very core
of American identity is a deep commitment to individualism and the individual’s
opportunity (and obligation) to succeed. American identity is also rooted in distinct
ethnic traditions, predominantly the Protestant traditions of America’s British settlers,
477
and this has been important in shaping American culture (Lipset, 1997). The
Protestant work ethic is part of this culture. Fukuyama (2007) argues that Americans
work harder than Europeans, and tend to believe in a similar fashion to the Weberian
interpretation of Protestantism, that dignity lies in morally redeeming work rather
than in the solidarity of a welfare state (Fukuyama, 2007, p. 3). The emphasis on
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individuality rather than the solidarity of a welfare state is the exact antithesis of the
European model, as suggested in the varieties of capitalism literature (Hall and
Lindholm, 2001). This leads to economic conceptions of citizenship based on work
(Katz, 2001). To belong, one must be worthy – i.e. economically productive (Shortall
and Warner, 2007). The dominance of the term ‘‘nonprofit’’ as the definition of civil
society is reflective of the American creed.
Thus, it can be argued that the dominant American theory of the nonprofit sector
presents a culturally specific and narrow definition of civil society, and limits cross-
national comparative research to a search for the American nonprofit sector in other
countries.

The European context

European research on civil society has also risen to the fore over the last couple of
decades, although there are differences across Europe in how the concept is approached.
While not as high-profile as the Johns Hopkins Project, some collaborative research
networks have developed across Europe. Probably the best known is the EMES. It is ‘‘a
research network of established university research centres and individual researchers
whose goal is to gradually build up a European corpus of theoretical and empirical
knowledge, pluralistic in disciplines and methodology, around ‘Third Sector’ issues’’[3].
This network exists since 1996, when ‘‘an international group of scholars formed a
research network that was sponsored by the EU. Having reached an unusual level of
mutual understanding, trust and a common perspective of working together, a community
of researchers sprang off from this working experience[4]’’. The network is also
developing an ‘‘ongoing dialogue’’ with researchers working in similar areas in North
America and other regions of the world. Thus, EMES organised the first European
conference on the third sector in 2005 in collaboration with the International Society for
Third-Sector Research (ISTR) which is an international network created by Salamon and
Anheier. ISTR network is located in Baltimore, where the Johns Hopkins Project
originated. Founded in 1992, ISTR promotes ‘‘research and education in the field of civil
society, philanthropy and the nonprofit sector’’[5]. The vocabulary here indicates the
‘‘American perspective’’ that other scholars have pointed out. However, it has to be said
that ISTR played – and still does – a crucial role in expanding and stimulating the
development of third sector research. Further, it should be noted that the European ISTR
Regional network is located in England, in the Charities Aid Foundation. EMES, on the
other hand, is located in Brussels. It actually seems to be more of a ‘‘Continental and
Northern
 IJSSP Europe’’ network, as the founding members (as well as current individual members)
29,9/10 seem to be mostly from Germany and France, as well as Norway, Denmark, Finland,
Sweden and recently Poland.
Alongside these two European networks, there is a third significant network. The Third
Sector European Policy network, which focuses on narrower issues (such as the European
third sector policy) originated in the Centre for Civil Society of the London School of
Economics (LSE). In 2002, Jeremy Kendall secured funding with research partners from
478 eight other European partners to initiate comparative empirical work on third sector
European policy under the European Commission’s 5th framework. The focus of the
project developed out of work by Kendall and Anheier at the Centre for Civil Society on
the policy analysis of the role of the third sector in EU policy making.
There are, however, cultural differences in the terminology referring to civil
society across Europe. It is to these concepts that we now turn.
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The third sector

The third sector is a term for civil society that has much greater currency in Europe
than the USA, particularly in France and Southern Europe. The contemporary
revisiting of civil society began with the work of Etzioni and Levitt in 1973. Etzioni
referred to the trichotomy of State, market and the third sector, although the latter was
initially referred to as the ‘‘public sector’’. For Etzioni, the public sector is everything
that is not purely governmental or profit oriented (1973, p. 316). Etzioni includes (or
at least does not exclude) informal networks and families in the third sector. Etzioni’s
definition provided an important starting point for current debates:
It is wide enough that it does not accidentally exclude some interesting phenomena, but it is
so wide that it has not been used much in third sector studies (Muukkonen, 2000).

According to Defourny et al. (2000), of all designations employed to describe the

activities that do not fit the classical categories, ‘‘third sector’’ is without doubt the
expression over which there is the widest international agreement among researchers.
However, Mertens points out that
The concept of the third sector generally held in French-speaking cultures [and] needs to be
appreciated within the context of an environment conditioned by State interventionism and
by the existence of already long-standing communal organisations. In France and Belgium
the welfare State does indeed provide and performs by itself a good deal of those activities
that are entrusted to the third sector in [Anglo-Saxon traditions] (Mertens, 1999, p. 516).

Former European Commission President Jacques Delors introduced the concept ‘‘third
sector’’ at the end of the 1970s. He published an article – ‘‘Pour la creation d’un troisie`me
secteur’’ (‘‘For the creation of a third sector’’) in which he analysed the emergence in the
1970s of ‘‘a large number of initiatives by young men and women who wanted to start up
new activities and were looking for other legal frameworks than those available at the time
(such as cooperatives, associations and of course the private-sector profit-making
companies)’’ (Delors and Gaudin, 1979). He built on the report to call for the
establishment of a legal and financial framework that could promote the development of
such initiatives and the creation of employment. The debate moved on in the late 1990s
with the publication of Lipietz’s report into the third sector. The third sector was the term
used to describe all socio-economic activities not part of either the market or State arenas,
or which also have a dimension of ‘‘social, environmental or cultural utility’’. The third
sector was to be ‘‘a space, identified by a common label,
 essentially encompassing the social and solidarity-based economy as currently Civil society as a
understood, but with a possible extension into the private sector’’ (Lipietz, 2001).
contested field of
Evers and Laville (2004) argue that the term third sector is often used because it
appears as a neutral term, free of an a priori link with any theoretical or ideological meanings
tradition. This, however, implies that the same word, ‘‘third sector’’, can have
different meanings. Consequently, there are a number of interpretations of the third
sector that enjoy a level of currency at the European level. The first is that of a third
sector perceived as not-for-profit sector or services of general interest. The second is
479
of organisations which present themselves as advocacy groups in the process of
European civil dialogue. ‘‘The risk of this approach is that it underestimates the
economic dimension of the third sector and denies it a voice within European social
dialogue’’ (Fraisse, 2002). The third concept is of social enterprise, seen as one of the
four entrepreneurial models within Europe: for-profit enterprises, public enterprises,
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family enterprises and social enterprises (Fraisse, 2002).

At a research level, the term third sector reminds us that third sector organisations do
not operate in isolation (Mertens, 1999). However this can be challenged (Curry-
Smithson, 1995). At least in historical or evolutionary perspective this sector could be
considered as first, or prior to either State or market. Others point out that ‘‘third sector’’ is
‘‘principally the vocabulary of political scientists, several of whom have read too many
economists’’ (Thayer Scott, 1999), meaning here that the economic approach is still very
much dominant in the term ‘‘third sector’’. Indeed, it seems that, for most French thinkers,
the sector can be considered as ‘‘a sphere of economic activities that occupies the space
between the point where the private sector ends and the point where the State sector
begins’’ (Landeau, 1995). Again, the development of this concept is culturally specific. In
France, civil society was viewed with suspicion as interference in the relationship between
the citizen and the state. It seems appropriate then that the state introduced the concept of
the ‘‘third sector’’ as the synonym for civil society.

The voluntary and community sector

Karl (1984) argues that the etymon voluntary refers originally to religious concerns.
From there it spread to military service and agriculture. He also notes that an
important controversy has always been present in discussions of the volunteer,
namely whether volunteers are better at their duties than professionals.
In the modern usage the term has two connotations (Muukkonen, 2000). First, the
main reference is to volunteering as a phenomenon in different organisations. In this
sense it distinguishes itself from professionalism, but it does not identify the kind of
organisations in which volunteering occurs. Second, the term refers to the character of
the organisations. Voluntary organisations are formed freely to satisfy the needs of
people. While the concept of a voluntary sector seems easy to identify in the UK, it is
much more difficult to recognise elsewhere. It is worthy of note that the Centre for
Civil Society in the LSE was previously the Centre for Voluntary Organisation. The
voluntary sector in the UK has its roots in the philanthropic organisations that
developed with industrialisation. While economic success at this time was seen as an
expression of God, visible displays of wealth were not, and a philanthropic culture of
contributing to charitable foundations and undertaking programmes of social reform
developed.
Leat (1997) criticises the implicit assumption in the definition and promotion of
‘‘voluntary sector’’ that this is ‘‘a discrete sector which contributes particular
characteristics to the welfare mix flexibility, closeness to the customer and so on’’, while
 IJSSP larger organisations in the voluntary sector can lay less claim to these attributes.
29,9/10 Taylor (2004, p. 124) stresses that their critique is reflected in the increasingly
common use of the phrase ‘‘voluntary and community sector’’ to describe the sector in
the UK. Taylor explains that this distinction has been promoted by a Community
Sector Coalition, set up to ensure that the interests of smaller, more associational
organisations are not crowded out by those of larger, more professionalised and
formally organised ‘‘nonprofit organisations’’ (Taylor, 2004, p. 125). Consequently,
480 the term voluntary sector includes, or sits alongside, the community sector. Reference
to the voluntary sector generally means both the voluntary and community sectors. In
both cases, it usually means service delivery organisations.
However, the term ‘‘community’’ itself is not without problems, as it is ‘‘often based on
unarticulated assumptions and can carry a range of meanings’’ (Kenny, 1999, p. 7). Thus,
the ‘‘elasticity of the concept of community allows diverse intellectual and political
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traditions to lay claim to it as a unifying symbol’’ (Powell and Geoghegan, 2005, p. 139).
As Schuler (1996, pp. 2-3) stresses, the term community can be used in various ways: it
can refer to a group of people living in a contiguous geographical area; it can identify a
group of like-minded individuals; or it can refer to a ‘‘sense of community’’ that
individuals in a group feel when they belong to a greater social unity. Communities are
social constructs which tend to change over time and space. According to Hughes and
Mooney (1998, p. 72), ‘‘communities are always imagined’’. The ‘‘nation’’, for instance,
has been imagined as a community with a limited membership and based on a ‘‘deep
horizontal comradeship’’, binding together people who do not know each other and who
will never meet (Anderson, 1991, pp. 6-7). Whatever the scale and the nature of the
community, it usually implies a sense of common identity. This identity ‘‘may be based on
shared class, geographical location, cultural values, gender, race, ethnicity, disability,
workplace or age, or it may be self-defined on the basis of similar political or other special
interests’’ (Kenny, 1999, p. 38).
While the concept of the third sector emphasises the notion of structure, the
voluntary sector concept focuses more on the notion of practice (Simonet, 1998, p.
58). The community sector tends to emphasise the notion of identity, and to a certain
extent place and location. Further, regarding the meanings of the voluntary sector, it is
important to note that it is also possible to find voluntary action within public/State
administrations, such as public or private hospitals. Besides, scholars such as Perri
and Leat differentiate between ‘‘the ‘invention’ of a sector [and] a looser, earlier
definition of voluntary action as a ‘style’ or ‘principle’ ’’ (Perri and Leat, 1997).
According to Whelan (2000, p. 10), ‘‘the voluntary sector is part of what the
economist Friedrich Hayek described as the third sector, distinct from the State on the
one hand and the commercial sector on the other’’. However, through volunteerism in
State organisations, the concept of the voluntary sector expands itself to the sphere of
the State and, therefore, differs from the other concepts.
Both the concepts of voluntary sector and third sector reflect contrasting traditions and
understanding of the welfare State, society, solidarity, and citizenship in Europe. The
concept of voluntary sector held in Anglo-Saxon countries (Simonet, 1998, p. 57) is
associated with a liberal vision of society, under which individual rights and benefits are
emphasised as a means to personal autonomy. The notion of the third sector seems to
emanate from a Continental tradition, and particularly a French one, where the idea of
‘‘one indivisible Republic’’ emphasises the third sector as a part of a whole society and
suggests that the ‘‘associative sector’’, as the third sector is also called in France, is a
social agent and a means to ensure social inclusion (Simonet, 1998).
 The social economy Civil society as a
While the term social economy originated in Europe, it later emerged in North America, contested field of
particularly in Canada and Quebec with its ties to the UK and France as well as other
European countries, especially Germany and Belgium (Laville et al., 2005b). meanings
The term ‘‘social economy’’ first appeared in France during the first third of the
nineteenth century. The concept of social economy was brought to the fore in the
nineteenth century by French-speaking economists Gide and Walras (Fraisse, 2002) 481
who wanted to reinvent economics to centre on new fundamentals (Bidet, 2000). At
that time, the social economy was defined as a new scientific discipline whose
purpose and methodology were complementary and distinct from political economics
or pure economics.
The idea of social economy covered a much wider area than today, although cooperatives,
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mutual benefit societies and nonprofit organizations already occupied a central position
(Defourny, 1992, p. 27).

For a long time, its meaning was much broader and amorphous than it is today. However,
along with the parting of these movements (cooperatives, mutual societies, associations)
the importance of the concept diminished. The concept of social economy was adopted
again in the 1970s when these movements became close to each other. No longer
describing an academic discipline, it is now used to identify forms of economic
organisation in which mutual societies, cooperatives, and associations, notwithstanding
their differences, can all find common identity and aims.
The concept of social economy refers to organised activities which aim at serving the
community, are being built on democratic values, and are organisationally independent of
the public sector. These social and economic activities are run mainly by associations,
cooperatives, foundations and similar groups. The main driving force of the social
economy is the benefit of the public or the members of a particular association, and not
the profit motive. According to Veron (1995, p. 35, in Muukkonen, 2000), the main
characteristics of social economy organisations are independence from the State; ‘‘one
man – one vote’’ – principle; and the social nature of the activities. Moreover, these
organisations hold values like the right to associate, democratic control, solidarity, justice
and equal opportunities (Muukkonen, 2000). Defourny adds the ‘‘absence of a profit
motive, freedom of membership, democratic management and independence from public
authorities’’ (Defourny, 1992, p. 36). According to him, social economy is a synonym for
‘‘the economics of social matter’’ (1992, p. 36). Defourny also refers to Desroche’s
suggestion that social economy has some common ground with its four boundaries, with
which it interacts: public sector, local public sector, private sector and trade union sector
(Defourny, 1992, p. 37).
According to Van Til (1988), the concept of ‘‘social economy’’ represents the
unique combination of purpose and organisation involved in effective voluntarism.
This concept draws fully on the democratic theories of populism, idealism, pluralism
and social democracy. It clarifies a position for voluntary organisations in society, and
it suggests a variety of productive roles for individuals, both inside and outside formal
organisations.
Thus, Defourny et al. (1999) explain:
Anyone can develop their own a priori conception of the social economy, simply by placing more
or less emphasis on either its economic or its social dimensions, both of which are wide-ranging.
In the final analysis, any economic phenomenon that has a social dimension, and any
 IJSSP social phenomenon that has an economic dimension, could be considered part of the social
economy.
29,9/10
In the EU, the concept of social economy challenges the American concept of
nonprofit sector and the British/Irish concept of voluntary (and community) sector.
Social economy was adopted as an official EU term in 1989. Helander (1998) believes
that this might lead to reformulation of the whole third sector concept (Helander,
482 1998, in Muukkonen, 2000). However, Fraisse (2002) notes that despite the lobbying
effort, the European Commission does not always use the term ‘‘social economy’’,
talking instead of the third sector, third system, or civil society. Although the notion of
the social economy is relatively widespread in Southern Europe (France, Spain, Italy,
Portugal, Greece) and Belgium, it is little used, even sometimes avoided, in the UK,
Germany, Scandinavian countries, and Eastern Europe (Fraisse, 2002).
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Some conclusions
The idea of ‘‘civil society’’ as a sphere of social life separate from the State took shape in
the late eighteenth and early nineteenth centuries. As it did so, it took different forms
(Seligman, 1992, pp. 10-11) and we argue that these are still visible in the more
contemporary language that has emerged to describe civil society. One tradition reflected
the French revolution, found in the work of Frederich Hegel which viewed civil society in
a generally unfavourable light, seeing it as an interference between the citizen and the
state. The other is the Anglo-American conception, which views civil society as the
ultimate repository of individual rights and liberties that must be protected against
incursions by the State. In the latter school of thought, civil society is seen as a self-
regulating universe of associations committed to provide a buffer against undue intrusion
by the State into the life of the individual (Nisbet, 1962). When the term ‘‘civil society’’
came into popular usage in the 1970s and 1980s, it reflected these earlier traditions.
Contemporary American political theories are rooted in an economic understanding
of civil society, and the nonprofit sector is the dominant terminology. European
approaches on the other hand include a social-political dimension. European theories
tend to be embedded in theories of citizenship and the welfare State (Wuukkonen,
2000). Therefore, we argue that not only is civil society framed differently in different
research traditions, but culture and national history also frame this singular social
space differently. Thus, the country of origin has as much influence in the
development of the various concepts of this arena as has the academic discipline or
the availability of data on the subject.
This article exposes a number of limitations of each of the terminologies used to
describe civil society. They all present a much more limiting notion of civil society
than that proposed by the founding fathers. None seem to capture the range of civil
associations in any society. Yet, assumptions are made that the terminologies used
have similar meanings rather than attempting to clarify and define exactly what is
being written or described (Deakin, 2000). This is exacerbated by the interchangeable
usage of nonprofit/third sector/community and voluntary sector/social economy. In
order to progress beyond culturally specific understandings of civil society, it is
necessary to examine the terminology used and how it emanates from a specific
cultural and political context. Having a clear understanding of the language used and
what it signifies is crucial to robust cross-national comparative research. This article
examines context specific understandings of civil society and the terminology used to
define it; a question not previously addressed. It is hoped that this article will generate
much needed further debate on cross-national meanings of civil society.
 Notes Civil society as a
1. We are mindful that an American/European comparison is partial. Considerable insight contested field of
could be gained from an examination of Russian, African and Asian understandings of
civil society. This however is a research project for the future. meanings
2. In 1996, the second round of research started among 27 countries.
3. EMES: www.emes.net/index.php?id¼7
4. EMES: www.emes.net/index.php?id¼7 483
5. ISTR: www.istr.org

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About the authors

Sandrine Roginsky was awarded funding from the Royal Irish Academy to complete her
comparative PhD thesis on the Third Sector and Social Change at Queen’s University Belfast,
Northern Ireland. She now lives in Paris, working as a Research Fellow for the European
Parliament. She also holds part-time appointments in Paris-Sorbonne University and in Paris 12
Val de Marne University. Sandrine Roginsky can be contacted at: sandrine@verts-europe-
sinople.net
Sally Shortall is a Reader of Sociology at Queen’s University Belfast, Northern Ireland. She has
over 70 publications in rural sociology and rural social policy, and research grant earnings of over a
million pounds. She is currently an ESRC Fellow in the Department of Agriculture and Rural
Development Northern Ireland. Sally Shortall can be contacted at: s.shortall@qub.ac.uk

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