Negotiating the Boundaries of Equality in Europe

Bertossi, Christophe.

The Good Society, Volume 12, Number 2, 2003, pp. 33-39 (Article)

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DOI: 10.1353/gso.2004.0002

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 SYMPOSIUM

Negotiating the Boundaries of Equality in Europe

Christophe Bertossi

In 1999 the European Commission asserted that “the right to the relationship between the State of right and the capitalist mar-
equality before the law and the protection of all persons against ket. The second is republican. It adds solidarity and collective
discrimination (. . .) is essential to the proper functioning of dem- identity as a sine qua non of the polity; cohesion is seen as the
ocratic societies. (. . .) It has never been more important to under- third source of citizenship (Habermas, 1996: 21).
line these principles” (Commission of the European What is striking is the way by which this second paradigm
Communities, 1999. Emphasis added). There is much to be learnt has dominated debates on citizenship and immigration in Europe,
from this passage. This “forward-looking” assessment seems to both in the academic literature and public policies.
dismiss the relevance of past policy experiences regarding citi- Citizenship returned to this dual agenda when immigration
zenship in Europe (Flew, 1989: 166). Why is that so? shifted from an economical issue to a political “problem” in the
My argument is that this line on equality-cum-discrimination mid-1980s. The promotion of national citizenship among European
is part of a shift from formal and state-orientated citizenship to immigration countries entered center-stage of the political agenda
substantial citizenship. This shift is nurtured by debates on the when the modern nation-states started to face critical limits in
modern framework of the nation-state, limits of the national for terms of sovereignty and membership, the latter being challenged
embodying equality, and the liberal dilemma of diversity. by increasing migratory flows, the parallel process of migrants’
In other words, European policies are now recognizing the durable settlement and the European integration.
existence of a “European Dilemma,” in the same way Myrdal It is clear that the concomitance between the renewal of cit-
spoke about An American Dilemma (Myrdal, 1944), and Jim izenship (rights and membership) and the “problem of immi-
Rose applied it to late 1960s Britain (Rose, 1969). Does it mean, gration” (Balibar and Wallerstein, 1991) has enhanced republican
as Rose claimed in his time, that we are subsequently witness- positions. For Christian Joppke, for example, “citizenship is both
ing a “liberal hour” for citizenship and a legal status and an identity, fusing the
immigration in Europe? In short, to divergent legacies of territorial state-
what extent may the development of My argument is that this line on ness and republicanism” (Joppke 1998:
European policies contribute to the for- equality-cum-discrimination is part of 23). In this view historical, sociologi-
mation of a new paradigm of citizen- a shift from formal and state-orientated cal, political and normative conditions
ship? If it exists, can the latter citizenship to substantial citizenship. of citizenship would be necessarily
incorporate non-EU foreigners into This shift is nurtured by debates on embodied in the congruence between
active citizenship? Do European the modern framework of the the individualist ethos and national
national policies of citizenship converge nation-state, limits of the national modernity (Aron, 1991; Leca, 1990;
on a mainstreamed framework? for embodying equality, and the Stinchcombe, 1975).
To provide some analytical elements liberal dilemma of diversity. Subsequently, the very recognition
addressing those questions, I start with of ethno-cultural and religious diversity
a critical approach of the republican has been set in terms of a challenge to
arguments that shape the formal understanding of equality and the congruence that exists in the Rousseauist tradition between
citizenship, both in public policy and scientific literature. Then membership, allegiance and equality of rights.
I turn to the nexus of transformation regarding citizenship, Therefore, citizenship has been profoundly affected by a
namely the challenge of European integration and the emergence never-ending “war of gods” (Weber, 1978) crystallizing the oppo-
of the anti-discriminatory agenda. I conclude questioning whether sition between identity and equality, but also homogeneity and
this process can get rid of the republican paradigm characterised plurality, essentialism and constructivism, structures and agency,
by a paradoxical reactive obsolescence. liberalism and communitarianism, republicanism and multicul-
turalism (Isin and Wood, 1999). This discussion has been an end-
Republican Limits state issue. It has also well developed as a core instrument of
Jürgen Habermas distinguishes between two main streams of public policies. Adrian Favell interestingly outlines that politi-
political thought. The first is liberal. It embodies citizenship in cians “depend increasingly on making dogmatic stands about

The Good Society, Volume 12, No. 2, 2003 • Copyright © 2003 The Pennsylvania State University, University Park, PA 33
 SYMPOSIUM
sacred national values, virtues and ideals” (Favell, 1998: 248) societies, paralleling the post-colonial ambiguities and pater-
precisely when they lose control and responsiveness over the nalistic favours of the politics of religion.
public problems. For example, when integration was debated in Jacobin France
This is worth mentioning because it highlights how far repub- in the mid-1980s, it became clear that Islam was the central issue.
lican tradition has reached a paradoxical situation: republicans One of the main justifications of the 1993 restrictive reform of
have succeeded in asserting collective identity as a pre-condi- French nationality was that “Islam is not only a religion, but a
tion of citizenship. But they have done so when the very mod- genuine rule for social, juridical, philosophical and economical
ern frames of citizenship have blurred. The force of life, which is opposed to our own conceptions, as well as our
republicanism is then its probable reactive obsolescence. The own principles” (Assemblée Nationale, 1993: 347). This not only
framework in which it appeared is profoundly challenged illustrates the French policy attitude to Islam, but also reflects a
(Westphalian nation-state order with low migration) (Turner, more general feature (Joly, 1995).
1993), and yet the questions it raises remain obsessively strong In these circumstances, then, how is it possible to extend the
(cohesion, civility and the public/private divide). boundaries of membership? Under which conditions and for
which results? As Rainer Bauböck puts it, “for a liberal con-
Integrating the “Other” ception, in contrast with the republican tradition of Aristotle,
This is particularly clear regarding Rousseau or Hannah Arendt, the inclu-
the politics of integration in Europe. sion of the inactive and even the incom-
But this “political” identity yields petent as equal members in the polity
Integration addresses the question of
cohesion and legitimacy of the polity
ground to politics of cultural and is a basic achievement of contemporary
that faces an on-going centripetal
religious identities versus national democracy” (Bauböck, 1994: 202). The
process of fragmentation (Wieviorka,
identity. In other words the republican approach suspects outsiders
1996; Isin and Wood, 1999). It is an disintegration of national identity of resisting integration under the pre-
issue of guaranteeing a “moral public is assessed as a challenge to tence of their “encumbered identities”
order” above competing values, attitudes political cohesion. (see Miller, 2000). This is not to point
and interests. This Hobbesian question at resistance to integration as a more
(Favell, 2001: 2) obtains a peculiar resonance in the context of efficient or even successful strategy by
mass migration and durable settlement that leads to the dilem- which newcomers might obtain their franchise. The argument is
mas of liberal societies. limited to the “thin consistency” of their civic virtue. This echoes
The problem of integration is dual. On the one hand, Western the 19th- and first 20th-century exclusion of non-owners and
societies encounter a crisis of the school system (Dubet, 1987), women from political rights.
massive unemployment and changes in modern forms of socia- However in that case, the question of allocating rights and
bility that lead to a crisis of Welfare and citizenship in terms of membership to newcomers is directly linked to the fear of a loss
social mobility and political representation. of identity. Nationality reforms in Great Britain (1981) and
On the other hand, it is about integrating ethno-cultural and France (1993–8) or Germany (1999) appeared as resulting from
religious diversity into the classical strands of an equality-based the politicisation of immigration in these terms. Citizenship
society. As far as immigration is concerned, integration becomes extension (or restriction) had to go through nationality reforms,
a policy issue aimed at “cultural” attitudes and behaviours that based on the political consensus for which a liberal society has
would challenge the “core values” of Western societies. This the right to limit the rights (compare Arendt’s “right to have
underlies the blurred boundaries between integration and assim- rights”), as far as this is articulated to the political principle
ilation. More importantly, this hides how far social marginal- grounding the modern state’s legitimacy and moral order: the
ization does affect more deeply those who are suspected of nation.
“bringing in their luggage” the integration problem. In the same token, integration still dominates literature even
European national politics of identity have sharply illustrated if it appears as a loose concept, less defined by what it is than
these limits as far as Islam has been concerned. Whereas Islam what it opposes (i.e. Durkheimian anomie, segregation or majori-
became the second religion in Europe after the shift from influx tarian democracy, etc.). Integration also lays claim to understand
migrations to durable settlement and family reunification, citizenship in terms of homogeneous (or consensual?) political
Muslims represented the radical “Other” that could not possibly identity (see Van Gunsteren, 1997). But this “political” identity
be incorporated into Western citizenship framework. Islamo- yields ground to politics of cultural and religious identities ver-
phobia has been a common feature of contemporary European sus national identity. In other words the disintegration of national

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identity is assessed as a challenge to political cohesion. The polit- ical conceptions of identity and pluralism; a separation between
ical becomes in its turn an issue of belonging (Castles and citizenship and nationality. The argument here is that the array
Davidson, 2000). of those social and political processes shapes transformations in
the citizenship question that cannot fit in the republican dream
Citizenship and the European Challenge anymore.
Within this broad republican understanding, negotiations on— Beate Kohler-Koch shows that the European governance is in
and transformations of—citizenship are reduced to a single itself a process for such a change. In this perspective European
process, namely the dialectic between national identity, new- integration extends the political beyond nation-states and builds
comers’ imported identities and integration. This not only under- up “a political system which is not—and, in the foreseeable
estimates the possible impact of European integration on national future, will not be substituting for—the nation-state” (Kohler-
policies, but also it lacks any tools for addressing the EU chal- Koch, 1999: 15). Then, “being a member of the EU is con-
lenge and the articulation between different levels of citizenship comitant with the interpenetrating of systems of governance; any
(local, national and supranational). Rogers Brubaker’s work illus- policy which is part of such a ‘penetrated system’ is bound to
trates those limits. He argues that citi- change in terms of established patterns
zenship is deeply rooted in historical of governing” (idem).
This highlights key loci of
and political legacies, “mediated by self- This echoes Meehan’s diagnostic of
transformation, namely the extension a spillover from European social regu-
understandings, by cultural idioms, by
of citizenship realm beyond the lation into the legal and political regu-
ways of thinking and talking about
nation-state and the European policy lation of Member States (Meehan,
nationhood” (Brubaker, 1992: 16; for a
development; the articulation between 1993: 146). Actually, citizenship is
critique see Behnke, 1997).
the social and the political; the embedded in a dialogical relationship
At the extreme opposite of this con-
negotiation between “homogeneous” between social rights and political fran-
servative line, some authors have seen
in the European integration a clear step
political conceptions of identity and chise. This is of Marshallian vintage.
away from the nation-bounded citizen-
pluralism; a separation between For Marshall, the State of right and the
ship. Yasemin Soysal argues that a post-
citizenship and nationality. The capitalist market are not sufficient agen-
national institutional framework is argument here is that the array of cies for sustaining an equality-based
emerging that replaces the nation-state those social and political processes society (Marshall, 1950). Social rights
politics of immigration and citizenship shapes transformations in the complete the citizenship apparatus of
(Soysal, 1994). In short, citizenship is citizenship question that cannot fit civil and political rights, balancing
shifting from “nationhood” to “person- in the republican dream anymore. inequality generated by the market.
hood,” that is membership directly Therefore one of the key elements of
embodied in the Human Rights international regulations and Marshall’s definition is the interde-
agencies. Ethnic minorities can therefore counter-pass the nation- pendence between the threefold set of civil, political and social
states legal order (i.e., through supranational courts) (see rights, working as a dynamic of extension of citizenship mem-
Feldblum, 1998; Castles, 2000). bership (Castles and Davidson, 2000; Soysal, 1994).
In between Adrian Favell argues more accurately that the low The context of migration-settlement has renewed this ques-
level of real policy implementation at the European level paral- tion about the closure element of citizenship. Beyond social poli-
lels the fact that, at national levels, “the margin for adaptation and cies that have blurred the legal boundary between nationals and
change is small and that there is little sign of competing ideas foreigners, a step further is to question whether the final dis-
coming along internally to mount a positive challenge” (Favell, tinction can be abolished, that is, the “hard” political franchise.
2001: 241. Emphasis added). Where then can we find a dynamic It clearly represents an ideal for European institutions. The
of change? I think the pressing question might be more relational: Presidency Conclusion of the 1999 Tampere European Council
what is the articulation between the institutional and cultural attrib- claimed that “the European Union must ensure fair treatment of
utes of citizenship, and how has that articulation changed in accor- third country nationals who reside legally on the territory of its
dance with the scale of and shifts in European politics?1 member states. A more rigorous integration policy should aim
This highlights key loci of transformation, namely the exten- at granting them rights and obligations comparable to those of
sion of citizenship realm beyond the nation-state and the EU citizens” (Tampere European Council, 1999).
European policy development; the articulation between the social However, the institutional separation between nationality and
and the political; the negotiation between “homogeneous” polit- citizenship is far from matching those high standards. The 1992
Maastricht Treaty implemented a citizenship of the Union both

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at local and supranational levels (article 8). This citizenship and adaptation comes into play because of European social poli-
remains conditioned by the nationality of one of the Member cies echoing a bottom-up mobilization initiated by migrants and
States (Martiniello, 1994; Wihtol de Wenden, 1997). However, ethnic minorities on parallel claims.
if it is still limited rationae materiae (it excludes national citi- John Rex gives a further clue. In his Weberian approach of
zenship) and personae materiae (it excludes non-EU nationals), ethnic mobilization in multicultural societies, Rex shows that
foreign nationals are entitled to the rights of active citizenship the state, and subsequently its citizenship, are not stable entities,
on the basis of residence criteria. Consequently European national but a “site of struggle” among collective political actors that
constitutions have been reformed to allow this (still limited) sep- emerge and help to determine political outcomes (Rex, 1994;
aration between citizenship and nationality. Radtke, 1994). Actually bottom-up negotiations among migrants
and ethnic minorities have occurred in Europe, challenging
Discrimination and the European Dilemma national politics of identity, nationality reforms, integration nar-
The separation between citizenship and nationality, however, ratives, and the “management” of religious diversity. Their chal-
is at play in a less institutional definition of citizenship, beyond lenge to national citizenship has been aimed mostly at
the limits of the Maastricht Treaty. A post-colonial contexts, notions of loy-
model of European citizenship is emerg- alty and allegiance, and the homogene-
Publicizing the issue of discrimination ity of the public realm. This challenge
ing whilst discrimination is erected as a
is not a neutral social policy as far as to national citizenship as a framework
core issue of public policies.
citizenship is concerned. The normative for (restrictive) politics of identity has
Some authors have used Myrdal’s
value of legal equality yields ground to laid claim to the realization of citizen-
argument about an “American dilemma”
the issue of substantial equality. ship (Close, 1995).
and applied it to the European situation
(Schierup, 1998). As soon as the mid- Consequently, “being a citizen is
1960s, Jim Rose used the notion for post-war Britain, showing a much broader than being a national”: the lack of civil, social or
critical gap between the common creed of equality on which economical resources, the inequality of opportunity in educa-
British policies of citizenship were based, and the reality of eth- tion, employment or leisure have been publicized as the main
nic minorities being structurally discriminated against (Rose, areas in which contemporary citizenship is at stake (Bertossi,
1969). It was the first landmark in the public recognition of dis- 2001: 191–217).
crimination as a policy problem (Smith, 1968; Daniel, 1977; This attempt to socialize citizenship in regard of discrimina-
Brown, 1984), leading progressively to implementing the actual tion has found variable political opportunities at national levels.
race relation framework. 2 In this field, the less favorable country has been France. In the
Publicizing the issue of discrimination is not a neutral social French normative framework of citizenship, inequality based,
policy as far as citizenship is concerned. The normative value say, on ethnic or religious categorizations, has been ignored
of legal equality yields ground to the issue of substantial equal- because of the uniqueness of (public) individuals in the Jacobin
ity. In short, in a republican perspective, nationality is seen at ideology (see Schnapper, 1994). Consequently, the policies of
the same time as the condition and the guarantee of access to integration and citizenship have denied the existence of dis-
equal rights and membership. Naturalization and access to crimination in the French society, while ethnic minority associ-
nationality would be equivalent to a mechanical access to full- ations and their traditional allies of the voluntary sector and
fledged equality (Weil and Hansen, 2000). When discrimina- human rights organizations have promoted a public recognition
tion becomes a policy issue, this global picture becomes of the issue (Wihtol de Wenden and Leveau, 2001).
something totally different. Being a national is not synonymous Discrimination is also a top-down agenda. European institu-
with being a full-fledged citizen. Therefore the very legitimacy tions have based their approach of equality-cum-diversity on the
of national citizenship as an equality-generating agency is at emphasis of equality of opportunity (and of outcome) rather than
stake (Bertossi, 2001). abstract individual equality (often used as a means towards assim-
This may provide an element of the answer to the question of ilation). The European Commission, Council and Parliament
whether citizenship policies do transform, and if they do, where launched a common declaration from that perspective in 1986.
it is possible to find the site of such a change. Whereas chal- From the 1990s onward, numerous resolutions have been issued
lenging both Brubaker and Soysal, Adrian Favell argues there is claiming human rights as an aspect of citizenship in a context
no margin for change and adaptation, either at national (path of ethno-cultural and religious diversity.
dependency) or European levels (low level of implementation), These declarations of good policy intentions, however, par-
I think it would be more accurate to approach the ethnic dilemma alleled a low level of implementation. However, the 1997
from a quite opposite perspective. That is, a dynamic of change Amsterdam European Council stepped further and incorporated

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the fight against discrimination into the EU Treaty. Article 13 of
the Treaty addresses discrimination on the grounds of race and
ethnic origins, religion and belief, sex, disability, age and sex-
ual orientation. Two EU Council directives were adopted pur-
suant to this article: one addressing racial discrimination at large,
the other targeting all forms of discrimination at the work place.
This illustrates an EU policy trend that consists in merging anti-
discrimination as a mainstreamed strategy. That challenges for
example the British anti-discrimination apparatus which is based
on the separation between racial and ethnic (1976 Race Relations
Act and its 2000 Amendment), gender (1976), and disability
(1995) discrimination, and failing to take account of religious
discrimination.3
It is important to stress the impact this EU agenda has had on
national policies. The French situation illustrates probably the
most striking shift in that extent. In 1996, the Council of State
assessed that “being the basis of the juridical order of our soci-
ety, the principle of equality is threatened when new and serious
inequalities extend in the society (. . .). Equality of rights seems
to be a mere formal petition. Thus, the credibility of the equal-
ity principle is definitely at stake in the field of equality of oppor-
tunities” (Conseil d’Etat, 1997: 45). New implementations
followed in 1998–2000, notably the setting up of a new national
body (GELD), regional agencies (CODAC) and a hotline serv-
ice (the “114”).4 In the same token, the Law of November 2001
incorporates the EU Council directive on discrimination at the
work place.
Paraphrasing Meehan, it is in the resolution of competing
ideas about integration and the relationship between the eco-
nomic and the social that anti-discrimination has become a sig-
nificant element of European policy (Meehan, 1993: 59). Beyond
this, it has entered the core sphere in which citizenship is being
negotiated, involving also the political franchise. European cit-
izenship has found in this axis a central element for setting up
new understandings of citizenship that may respond to social
struggles and challenges to the republican nation-orientated cit-
izenship.
Republicanism Strikes Back
May all this end on a possible harmonization or convergence
of European policies of citizenship? And behind this question,
can a common European political identity emerge (see Habermas
1998)? My answer to this question is not a direct one. I would
argue that what I called the reactive obsolescence of republi-
canism broadly challenges the convergence perspective.
Opposing plural citizenship, a counter-agenda emerges in
Europe which crystallizes citizenship around issues of cohesion
and security. Civic virtues, national cohesion, welfare national-
ism become consensual views and win popular support. The over-
whelming resurgence of the far right across Europe is one cause
of great concern. Austria, Italy, Denmark, France and the
Netherlands have staged the rise of populist movements over the
last two years. So-called “New Policies of Immigration” picture
again Europe as a fortress.
Whereas, for example, the British race relations have become
paradigmatic of “good practice” (or “best value”) for European
policy-makers, they are being broadly challenged “from within”
today. Multicultural Britain yields ground to the temptation of a
republican polity, along lines promoted by the Home Office after
the riots in Northern England during the summer of 2001, and
over the issue of asylum seekers, illegal migrants, and transna-
tional features of post-colonial migrations (Home Office, 2001;
Commission on the Future of Multi-Ethnic Britain, 2000; Malik,
2001; Barry, 2001).
That leads indisputably to a sharp contradiction between the
emerging policy regarding citizenship, promoted by EU institu-
tions and subsequently implemented in the Member States, and
the very national policy agenda which considers diversity as a
threat to cohesion. Myriam Feldblum locates the parallel rise of
post-national and neo-national politics as two elements of the
same reality (Feldblum, 1998). However, the question is now
whether this divide only concerns political struggle and change
in power, or if it will become a feature of European integration,
opposing national and European levels. Despite this cause for
concern, I have argued that the question of citizenship has crit-
ically shifted in Europe, showing the politics of identity have
not, in any case, the same scale of opportunity that they had in
the 1980s. It may appear as a path on which the future of EU
citizenship will depend, especially while it is now part of the
“acquis communautaire” and will remain an issue of the com-
ing enlargement of the Union.
Christopher Bertossi is Research Fellow at the University of
Warwick.
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Endnotes
1. I am grateful to Robert McLaughlin who pushed me to clar-
ify this initial hypothesis.
2. It must be added that in the European countries the context
of settlement differs also whether political franchise is given or not
 EUROPEAN CITIZENSHIP
to migrants once they arrive. The British case appears as the excep-
tion here because commonwealth migrants obtained political citi-
zenship when entering the United Kingdom. Elsewhere, they may
have gained a local political citizenship (Ireland, Sweden, Norway,
Finland, Denmark and the Netherlands) or they have had to be incor-
porated into the receiving country’s nationality. The least favored
have been the Gastarbeiter in Germany until the 1999 reform which
incorporated jus soli into the 1913 German nationality law.
3. Except in Northern Ireland where religious discrimination is
addressed whereas racial discrimination is not.
4. Regional Commissions of Access to Citizenship (CODAC)
were established in February 1999 by the Ministry of Interior and
set up in every French département. They first appeared as an inter-
face between the populations who are discriminated against, public
services and representatives of the State, and local associations. A
Group to Study and Fight against Discrimination (GELD) was
launched in October 1999 by the Ministry of Employment and
Solidarity. It aims at analyzing the extent of discrimination in France
and to extend public knowledge. In parallel, it is also meant to pro-
vide policy-orientated advice to the government, and three reports
were published in 1999 and 2000. Eventually a hotline (called 114)
for victims of discrimination was created in May 2000 on which
114’s listeners can register their accounts of discrimination.
Volume 12, Number 2, 2003 39