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How national citizenship shapes transnationalism. A comparative analysis of migrant claims-making in Germany, Great Britain and the Netherlands


par  Ruud Koopmans  et  Paul Statham  |  publié en ligne le 7 mars 2005

Ruud Koopmans  :  Department Political Communication and Mobilization Wissenschaftszentrum Berlin für Sozialforschung (WZB) ruud@medea.wz-berlin.de
Paul Statham  :  Centre for European Political Communication (EurPolCom) Institute of Communication Studies, University of Leeds paul@ics-server.novell.leeds.ac.uk



Mots-clés  :  CitoyennetéDiasporaEtat-nationMondialisationRevendicationTransnationalisme
Zones géographiques  :  AllemagneGrande-BretagnePays-Bas


Résumé : Citoyenneté nationale et transnationalisme. Une analyse comparative des revendications des migrants en Allemagne, en Grande-Bretagne et aux Pays-Bas. -- Le transnationalisme parmi les migrants est considéré dans la littérature récente comme un trait important de la mondialisation qui transcende, se produit en dehors, au-delà de l'État-nation. Cet article défend au contraire la position selon laquelle il faut étudier tant d'une point de vue théorique qu'analytique comment l'État-nation interagit avec la mondialisation. D'une manière plus spécifique, l'article compare systématiquement la formation des communautés transnationales et des diasporas en Allemagne, en Grande-Bretagne et aux Pays-Bas. La dimension publique du transnationalisme telle qu'elle s'exprime dans les revendications et la participation des migrants et des minorités dans l'espace public est au centre de cet article. L'analyse primaire est basée sur des données originales sur les actes publics de revendication dans trois pays. Cette approche permet d'examiner l'importance des revendications transnationales par rapport à celles qui se manifestent dans les espaces nationaux. La comparaison cross-nationale permet d'analyser la variation entre les différents types de revendications transnationales se produisant dans trois pays différents tant du point de vue de la citoyenneté que des régimes d'intégration. Les données indiquent des différences cross-nationales significatives entre les niveaux et les formes de revendications transnationales qui peuvent s'expliquer par le type de citoyenneté utilisée par les pays pour inclure politiquement les migrants dans la communauté nationale. Les revendications transnationales prévalent en Allemagne, où l'État offre peu d'opportunités aux migrants d'exercer une influence sur le politique et qui les exclut symboliquement de la communauté nationale. De plus, la comparaison entre la Grande-Bretagne et les Pays-Bas montre que la manière dont les États transforment les migrants en citoyens importe. L'approche ouvertement multiculturelle des Pays-Bas constitue un environnement plus favorable aux revendications transnationales que le modèle d'incorporation britannique fortement racialisé et culturellement plus assimilationniste.


Abstract : In contrast to the recent tendencies within the literature to discuss transnationalism among migrants as important features of globalization that transcend, occur outside, beyond, or 'post' the nation-State, this article takes the position that there is more theoretical and analytic mileage in studying how the nation-State interacts with globalization. More specifically, the paper undertakes a systematic comparison of the formation of transnational communities and diasporas in Germany, Britain and the Netherlands, by focussing on the public dimension of transnationalism that is expressed in the claims-making and participation of minorities and migrants in the public sphere. The primary analysis is based on an original data-set on public acts of claims-making in the three countries. Our approach enables us to examine the extent of transnational claims-making relative to that in the national context, whereas cross-national comparison facilitates analysis of the variation between the different types of transnational claims-making that occur in three countries with different national citizenship and integration regimes. The data show that there are significant cross-national differences between the levels and forms of transnational claims-making by migrants, and that these are best explained by the type of citizenship which a country uses for politically including migrants in its national community. Transnational claims-making is most prevalent in countries such as Germany, where the State offers few opportunities for migrants to influence the political process and symbolically excludes them from the national community. In addition, the comparison of Britain and the Netherlands shows that it matters 'how' nation-States make migrants into citizens, with the more outspokenly multicultural Dutch approach providing a more favourable environment for transnational claims-making than the strongly racialised and culturally more assimilationist incorporation model of Britain.


Extracto : Ciudadanía nacional y transnacionalismo. Un análisis comparativode las reivindicaciones de los emigrantes en Alemania, Gran Bretaña y los Países Bajos. -- La literatura reciente considera el "transnacionalismo" de los emigrantes como un elemento importante de la mundialización que trasciende al Estado-Nación. Este artículo defiende, por el contrario, la posición según la cual es necesario estudiar analítica y teóricamente cómo el Estado-Nación interacciona con la mundialización. Más específicamente, el artículo compara sistemáticamente la formación de comunidades transnacionales y de diásporas en Alemania, en Gran Bretaña y en los Países Bajos. En el centro de este artículo se halla, en definitiva, la dimensión pública del transnacionalismo identificada a través de las reivindicaciones y la participación de inmigrantes y minorías en el espacio público. Un análisis primario ha sido realizado a partir de datos originales recogidos en actos de reivindicación que se han desarrollado en los tres países. Este método permite examinar la importancia de las reivindicaciones transnacionales en relación con aquellas que se manifiestan en un espacio nacional. La comparación cross-nacional permite analizar la variación entre los diferentes tipos de reivindicaciones transnacionales llevadas a cabo en tres países diferentes, tanto desde el punto de vista de la ciudadanía como de los regímenes de integración. Los datos indican diferencias cross-nacionales entre los niveles y las formas de reivindicaciones transnacionales. Éstas pueden explicarse a partir del tipo de ciudadanía utilizado por los países para incluir políticamente a los inmigrantes en la comunidad nacional. Las reivindicaciones transnacionales prevalecen en Alemania donde el Estado ofrece a los inmigrantes pocas oportunidades de influenciar la política, donde los inmigrantes se hallan excluidos simbólicamente de la comunidad nacional. La comparación con los casos de Gran Bretaña y de los Países Bajos demuestra que la forma que el Estado elegirá para transformar a los inmigrantes en ciudadanos goza de importancia. La orientación multicultural de los Países Bajos constituye un contexto más favorable a las reivindicaciones transnacionales que el modelo británico de incorporación fuertemente racial y más asimilador culturalmente.


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Sommaire
    INTRODUCTION1
POSTNATIONAL  MEMBERSHIP  AND MULTICULTURAL CLAIMS : SOME EARLIER FINDINGS
THEORETICAL PERSPECTIVES ON TRANSNATIONAL COMMUNITIES AND DIASPORAS
A THEORETICAL FRAMEWORK FOR UNDERSTANDING TRANSNATIONAL CLAIMS-MAKING
CITIZENSHIP AND MIGRATION IN GERMANY, GREAT BRITAIN AND THE NETHERLANDS
DATA COLLECTION10
THE COLLECTIVE IDENTITIES OF MIGRANTS IN THE PUBLIC SPHERE
TRANSNATIONAL AND NATIONAL CLAIMS-MAKING AND HOW THEY RELATE TO MIGRANT IDENTITIES AND NATIONAL CITIZENSHIP
CONCLUSION


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Texte intégral
   

In general studies of globalization, as well as in the more specific literature on transnational migration, the nation-state and national citizenship are not exactly en vogue. Anything beyond (‘postnationalism’), below (‘the local’, ‘devolution’), above (‘global discourses’, ‘supranational institutions’), between (‘transnational communities’), or circumventing (‘glocalism’, ‘global cities’) nation-states has the warm attention of the academic community. By contrast, the nation-state, if not ignored altogether, usually appears attached to prefixes such as ‘post-’, ‘trans-’ and ‘supra-’ suggesting its actual or upcoming demise. We do not want to deny that the (actual or potential) new trends that are addressed by these strands of research do not deserve attention. To some extent it is moreover legitimate to pay more attention to what is new than to that which remains the same.

What we take issue with, is the tendency in the literature to rely on one-sided and often unsystematic evidence for supposed new trends that undermine the nation-state. It is not difficult at all to find examples that fit postnational, transnational and other alternatives to the nation-state centered model. However, it is not warranted to derive far-ranging claims about the future of the nation-state or a fundamental transformation of global politics from such examples as long as we do not know how representative they are. Only theoretical and empirical approaches that do not relegate the nation-state to the domain of insignificance a priori can tell us something about the comparative extent of new trends, but equally important perhaps, only they can show us how the nation-state interacts with globalization. Even staunch postnationalists tend to admit that the global to an important extent manifests itself within the nation-state, and that nation-states are important actors promoting and shaping globalization and supranationalization on the international scene.

If there still are important differences among nation-states — which some authors contest — it follows that we may find global trends such as increased transnational migration, trade and communication or the growing role of supranational institutions such as the UN or the EU, processed very differently by individual nation-states and resulting in diverging outcomes. In other words, although there can be little doubt that globalization affects the nation-state, it cannot be assumed a priori that the nation-state becomes any less important, nor that cross-national differences become necessarily homogenized.

In this paper, we want to focus on one particular development in the migration field that is said to challenge the nation-state, namely the formation of transnational communities and diasporas. We will deal in particular with the public dimension of transnationalism by focusing on the claims-making and participation of ethnic minorities of migrant origin in the public sphere. This is arguably one of the most important aspects of transnationalism in that it involves an interpenetration of the public spheres and the political identities, organizations, issues, and conflicts of the sending country and the country of settlement, with potentially important consequences for both polities. It should however be clear from the start that our analysis will not allow us to say much about other forms of transnationalism, such as networks of reciprocity among family members and co-villagers, or business connections between the country of settlement and the homeland. Our analysis and data will allow us, however, to gauge the extent to which such transnational ties extend beyond the private or market spheres, become publicly contested and politicized, and affect the behavior and identities of migrants and ethnic minorities as citizens in the public sphere. A second limitation of our analysis which we have to mention from the start is that we focus on the transformations transnationalism may bring about in the country of settlement. Our data do not speak to the extent and forms in which transnationalism transforms the public spheres and political processes of the sending countries, which may well be different from its impact on the country of settlement2.

In an attempt to avoid the pitfall of studying transnationalism by looking only at examples of transnationalism, we place our analysis in a systematic comparative framework3. First, we put (different forms of) transnational claims-making into perspective by comparing them to such claims-making by migrants which is fully embedded within the national context of the country of settlement. Second, we compare transnational claims-making across three countries, Germany, Great Britain and the Netherlands, which display considerable variation in citizenship and migrant integration approaches. This allows us to see if, and how the extent and forms of transnationalism vary as a result of different national political opportunity structures for migrant claims-making. In order to control for the possibility that such cross-national differences as we may find are caused by differences among ethnic groups rather than by national opportunity structures, we, thirdly, compare similar migrant groups in different national settings, as well as different migrant groups within the same national setting.

Before moving to our analysis of transnational claims-making, we will first, in the next section, briefly discuss some of our earlier results regarding two other theoretical issues in the migration field, which are often linked to the concept of transnational communities. These are the claim of an emerging ‘postnational’ membership of migrants that renders national citizenship largely irrelevant, on the one hand, and the claim that migrants increasingly claim ‘multicultural’ group rights, on the other.

A number of authors have identified the emergence of a new form of ‘postnational’ citizenship or membership whereby rights now extend across borders, and supranational institutions and global legitimating discourses, have superimposed their authority over the nation-state with the effect of rendering national citizenship increasingly irrelevant as a source of rights to migrants (Jacobson 1996; Soysal 1994; Sassen 1998). In the European context, the postnational argument draws on the empirical case of the experience of guestworkers, many of whom stayed on and brought their families over after recruitment programs ground to a halt and restrictive immigration controls became the Western European norm. Although most former guestworkers did not take up national citizenship in the receiving country, they nonetheless over time came to enjoy many of the same civil and social, though not political, rights as full national citizens (Bauböck 1994). Postnationalists have taken the existence of these rights given to non-citizens as proof of the erosion of national citizenship as the main source of rights. They argue that migrants no longer even need to naturalize to the receiving country, but can successfully sustain their claims to residence and welfare by referring to universal rights of ‘personhood’ that have superceded national citizenship as the guarantor of migrant rights. The link of this argument to the discussion on transnationalism is that postnational rights obviously make it easier for migrants to move in transnational spaces: the more their rights are guaranteed and legitimated on the global level, and the less they depend on belonging to a particular nation, then the more freely migrants can move in between national contexts without the risk of losing claims to rights and entitlements.

The postnational argument has not gone uncontested. Important counterarguments are that (a) the codification and enforcement of supranational rights has not gone nearly as far as postnationalists claim (e.g., Guild 2001)4; (b) human rights are not something that has been imposed from the outside on nation-states, but they originate in the constitutions of liberal democracies themselves (Joppke 1998); (c) supranational regulation in the migration field far from automatically implies a strengthening of migrants’ rights, e.g., the EU’s Schengen and Dublin, which aim at co-ordinating border controls and exchanging information on illegal immigrants and asylum seekers; and (d) even if there is some truth in postnationalists’ argument that citizenship today is first and foremost about identity, the symbolic inclusion or exclusion of migrants through citizenship may have important material consequences, including the (de-)legitimation of xenophobia and the (un-)marking of groups for discrimination and racism (Koopmans 1999).

Ultimately, however, the dispute over postnational membership rights needs to be settled empirically. In an earlier paper (Koopmans and Statham 1999) we have examined the validity of the postnational thesis examining data on claims-making by migrants and minorities in Germany and Great Britain. We have found little, if any, support for the postnational thesis, according to which one would expect migrants to — not exclusively, but certainly to a substantial extent — organize supra- and transnationally, to direct demands at supranational actors and institutions, or to make claims on the nation-state referring to supranational rights, conventions and discourses. Only at most a few percent of all migrant and minority claims in both countries displayed such characteristics. Particularly the European Union, often championed as a prime example by postnationalists, was almost completely absent as an arena for migrant organizing or the addressing or framing of their demands (see also Favell and Geddes 2000).

In her version of the postnational argument, Soysal (2000) claims that postnational conventions and discourses provide an important legitimating framework for migrant claims to retain their own cultural identity. Thus, she links up with the second theoretical issue that we briefly want to discuss, namely that of multicultural rights. This perspective asserts that recent waves of non-European migration — and Muslims in particular — have created strong pressures for granting migrants special rights, or exemptions from duties on the basis of their cultural and religious difference from the rest of society. Thus, migration undercuts the vision of a unitary citizenship on the basis of equal individual rights on which the liberal nation-state rests5 — a development which is alternatively seen as a necessary correction to ‘white’ cultural hegemony, or as a threat to social cohesion and solidarity. For understanding transnationalism, multicultural rights are important because they imply a weakening of nation-states’ claims on migrants to assimilate to the national culture and of pressures to severe ties to their countries and cultures of origin.

Often-cited examples of such multicultural challenges by migrant groups are the French foulard and British Rushdie cases, but again, to what extent such spectacular cases are representative remains unclear. Our comparative analysis of migrant claims-making in Germany and Great Britain revealed that, although both countries have about equally important Muslim populations, claims for multicultural group rights were almost absent in Germany, but played an important role in Britain. We argued that this difference must be explained by the availability of an extensive race relations and anti-discrimination framework in the latter country, which moreover officially defines itself as a ‘multicultural society’. This provides opportunities for claims to rights for migrants in general, and for cultural rights in particular. In Germany, by contrast, migrants are excluded as ‘foreigners’ from the political community and also in other respects have few channels of access to make claims on the state or on other actors, such as employers. This suggests that pressures for multicultural rights depend at least partly on conceptions of citizenship and national identity in a particular setting and are not a quasi-automatic consequence of the cultural difference of today’s migrants.

Arguments about the emergence of transnational communities and diasporas are often underpinned by referring to postnational rights that enable migrants to move more freely, on the one hand, and to a growing acceptance of receiving states for multicultural difference which allows migrants to retain strong ties to their countries of origin, on the other. However, the transnational communities argument is not reducible to the effects of postnationalism plus multiculturalism. In particular, increasingly globalised capital accumulation and transfer, the increasing speed of communications, and the affordability of long distance travel have been identified as structural developments that favor the emergence of transnational communities and diasporas. Transnational migrants, according to this view, are able to use these facilities to a greater degree than ever before to establish ties that transcend national boundaries, and by crossing and recrossing them physically, electronically and financially, they increasingly produce a transnational social, cultural, political and economic world. Transnational migrants do not leave their origins and pasts behind, they take them with them, and by maintaining their networks, they begin to act as conduits between the two or more nations where they have connections. The transnational communities approach is often based on the findings of ethnographic and anthropological studies of migrant behavior which observe the increasing political, social, cultural and economic stakes that these groups have in several places across the globe, and the hybrid forms of identity which they use both in relation to their homelands, countries of settlement, and scattered kith and kin (Basch, Glick Schiller, Szanton Blanc 1994, Portes 1998, Portes et al. 1999). In this view, then, it is not so much the transformation of the basis of citizenship which is eroding the capacity of nation-states to politically shape migrants in their national image, but the de facto behaviour of migrants.

The concept of transnationalism is sometimes used so broadly as to encompass migration and immigrants per se. However, in a more meaningful and widely accepted definition, transnationalism consists of "the processes by which immigrants forge and sustain multi-stranded social relations that link together their societies of origin and settlement. We call these processes transnationalism to emphasise that many immigrants today build social fields that cross geographic, cultural, and political borders. An essential element is the multiplicity of involvements that transmigrants sustain in both home and host societies" (Basch et al. 1994: 6). This includes phenomena as diverse as import/export immigrant businesses, investments by migrants in the country of origin, sustained links among family members and co-villagers in the countries of origin and settlement, homeland-based cultural and religious organizations that set up branches in the country of settlement, as well as the mobilization of migrants by homeland political parties and social movements or the diffusion of homeland-based conflicts to the migrant community abroad. The defining characteristic of transnationalism in this sense, are sustained relations between one or more countries of settlement and a country or region of origin. Thus, the presence of ethnic minorities of migrant origin does not in itself constitute transnationalism, if these groups do not maintain significant and sustained interactions with their homelands. Religious belonging as such cannot be considered transnationalism, either, unless a religion is tied to one specific ethnic group from a specific origin, as is the case for Jews and Sikhs. Although some authors talk about ‘transnational religious membership’ (e.g. Levitt forthcoming), including Catholicism and Islam, this stretches the transnational communities concept so much that it becomes useless for analyzing the impacts of migration in the modern world. As Vertovec (2000: 11) argues, the great religions are "world traditions that span many ethnic groups and nationalities that have been spread by many other means than migration and displacement".

The revived concept of diaspora likewise is often used in an excessively loose way, as in Marienstras’ definition as "any community that has emigrated whose numbers make it visible in the host community" (1989: 125). Used more precisely, diaspora denotes a particular kind of transnational community that originates in massive emigration and dispersal — forced or at least propelled by considerable distress — of a group from a homeland to two or more other countries (Van Haer 1998). Compared to other types of transnational community, diasporas tend thus to be characterized by a strong orientation towards the homeland, coupled with a longing to return once the homeland has been achieved, or independence restored, or its present regime has been overthrown. Beyond the classical template of the Jewish diaspora, examples include the Armenians, Palestinians, Tibetans, Kurds, Tamils or Mollucans, as well as regime opponents from Iran, Afghanistan or Cuba6. Given the preoccupation of diasporas with nation (re)building, it should not come as a surprise that hard-core postnationalists such as Soysal cannot mobilize warm feelings for the concept: "The category of diaspora is an extension of the nation-state model, in that it assumes a congruence between a territorial state and the national community, and by implication a congruence between territory, culture and identity" .... "Focusing peculiarly on the ethnic axis of homelands and abroad, the theories of diaspora overlook the transgressions of national boundaries and collectives and forget the new ways by which immigrants experience and enact their membership" (2000: 3, 10-11).

Some approaches to transnationalism in the more general sense likewise acknowledge the persistence of an international world order run by nation-states (e.g., Rex 1996, Castles 2000). Indeed transnationalism may even become a way for nation-states to extend their international influence. Receiving states may come to see resident migrants as important opportunities and conduits for establishing links with the sending country and seek to further secure their allegiance by reducing the criteria for naturalisation. Conversely, sending states may loosen their direct claims of allegiance on emigrants — for example, by accepting dual citizenship — as a way of establishing a bulkhead in a wealthier receiving state, with the aim of stimulating a continued flow of economic resources and political connections from the centre to the periphery (Freeman and Oegelman 1998).

Against this view, another set of authors condemn the institutional framework of the nation-state to the dustbin of history. They define the particularist group identity claims of minorities and migrants as the important driving force in the creation of a new world order populated by unlimited numbers of ‘diasporas’ — in the loosest sense of the word — who celebrate their ethnicity at the gates of postmodernity (e.g. Tölöyan 1996). In a less cultural studies vein, others have made similar claims about ‘diasporas’ challenging the nation-state (e.g. Cohen 1997, Vertovec 2000). Against the globalization trends propelled ‘from above’ by transnational capitalism and nation-states’ efforts at supranational (de)regulation, several authors see migrant communities as a counterforce of ‘transnationalism from below’ (e.g. Portes 1997, Basch et al 1994, Smith 2001). Ultimately, such ‘transnationalism from below’ processes are often defined as acts of resistance and appropriation that occur in the face of global capital accumulation, whereby transnational migrants acquire a privileged political status as a group with resources to resist the onslaught of global capitalism.

In line with the perspective advocated in the introduction to the volume where a revised version of this paper is due to appear (Joppke and Moravska eds.), we argue for an intermediate position that sees transnationalism neither as a mere auxiliary to, nor as a gravedigger of the nation-state world order. We endorse Guarnizo and Smith’s (1998: 12-13) criticism of the idea of transmigrants as unbounded actors: "we wish to underline the actual mooring, and, thus, boundedness of transnationalism by the opportunities and constraints found in particular locations where transnational practices occur" .... "the fit between specific kinds of migrants and specific local and national contexts abroad shapes not only the likelihood of generating, maintaining or forsaking transnational ties, but also the very nature of the ties that migrants can forge with their place of origin."

In contrast to the polemical opposition of national citizenship and national approaches to migrant integration, on the one hand, and an unbounded transnationalism, on the other, this perspective focuses our attention on the interaction between the two. In particular, we propose to investigate how the extent and forms of transnational and diasporic claims-making are affected by the political opportunities and constraints set by the specific citizenship and integration regimes of Germany, Great Britain, and the Netherlands. Much may depend, in addition, on the specific triadic relation between migrants, their homelands, and the country of settlement, whether migration has been enforced by political oppression, occurred willingly as guestworkers for economic betterment, or was shaped in part by colonial allegiance and a past adherence to an empire that spanned several continents. In addition, characteristics of the migrating group and their attachment to a particular religion or to specific political aspirations and ideologies may play a role. As a result of such factors, some migrant groups may fit the ideal type of a transnational community more closely than others.

The basic features of the theoretical model which we want to follow for analyzing the claims-making of migrant communities is depicted in Figure 1. Following the triadic conceptualization of transnationalism, we see migrant claims-making determined by the interplay of three factors. First, we expect the opportunities and constraints set by national citizenship regimes and integration models to influence the type of migrant claims-making (arrow 1). Generally speaking, we expect migrants to be more inclined to make claims regarding their situation in the country of settlement where the state provides opportunities for them and their organizations to do so. Perhaps the most important factor here is whether migrants have the right to vote (which largely depends on them holding citizenship), but in addition such factors as the existence of equal opportunity and anti-discrimination legislation, state subvention and consultation of migrant organizations, or the availability of cultural group rights in domains such as education and the media will play a role. We will elaborate these factors in the next section.

Figure 1 : Theoreticel framework for the analysis of migrant claims-making

Image1

For now, we turn to the second determinant of migrant claims-making in Figure 1, which we have broadly labeled as "homeland influences" (arrow 2). As a corollary to citizenship and integration regimes on the country of settlement side, this includes the sending country’s policies with regard to its emigrants. While some sending countries stimulate their (former) subjects to assimilate to the host society, most have an interest in retaining their emigrants’ allegiance, if only in order not to lose the yearly inflow of remittances on which many sending countries’ economies heavily depend. One such instrument is not allowing the loss of the sending countries’ citizenship or making such loss costly to migrants (e.g., when they lose inheritance or land ownership rights), another is the direct control over emigrants by way of sending-state or sending-state-sponsored organizations in the country of settlement, such as the branches of the Turkish Ministry of Religion or the Maghrebian Amicales in many West European countries.

Further, the category of homeland influences includes the actual political situation in migrants’ country of origin. It may be expected, for instance, that independence struggles of ethnic groups (e.g., of the Kurds and Tamils), other intra-ethnic conflicts (e.g., among Muslims, Hundus, and Sikhs in India), foreign occupation (e.g., Palestine, Tibet), civil war (e.g. Algeria, Bosnia), or oppressive dictatorships in the country of origin (e.g., China, Iran) provide fuel for homeland-directed claims-making among "diaspora" communities of migrants from these countries. Apart from the direct "pull" such homeland conflicts exert on migrants, such conflicts have often also been the "push" factor behind the flight or exile of politically active migrants. Thus, migrant communities from countries with a high level of internal political strife or oppression often harbour a disproportionate number of ideologically, ethnically or religiously "conscious" members, who hold a diasporic identity and wish to remain involved in the homeland "struggle" from a (safer) distance.

If both sending and receiving country share an interest in retaining migrants’ ties to their homelands, the activities of sending-country organizations in the country of settlement may be institutionally sponsored by both. Thus, the Bavarian and Turkish governments have together set up Turkish-Islamic classes in Bavarian public schools for "guestworker" children, which are given in the Turkish language by teachers sent over by the Turkish Ministry of Religion. This is one example of the ways in which the relation between the country of settlement and the sending country may influence both sides’ policies with regard to immigrants or emigrants, respectively (arrow 3 in Figure 1). The Bavarian example illustrates the guestworker type of relationship, which was usually based on bilateral agreements and based on the — as it turned out — flawed idea of temporary labor migration. A second important type of relationship is that between former imperial powers and their former or remaining colonies. Migrants from former colonies often enjoy — at least for a transitional period after independence — a right to citizenship in the "mother" country, or, in some other cases (e.g., Spain vis-a-vis its former South American possessions), can obtain citizenship more easily. In addition, of course, there are important pre-existing cultural linkages, most importantly the fact that many colonial migrants already know the language, which may make it easier for migrants to integrate into the host society. The other side of the coin is that the legacy of colonialism may also include deep-seated racism and paternalism with regard to former colonial subjects, which may counterbalance the integrative effects of cultural linkages. A final crucial type of sending-receiving country relationship in the European context is the case of intra-EU migration. Migrants from other EU countries nowadays hold largely similar rights (e.g., freedom of movement and access to the labor market) as native citizens of a member state and are in many respects — not least of all in public discourse — privileged vis-à-vis less well-seen "third-country nationals" or "extracommunitari". The only — though certainly not unimportant — exception are voting rights, which intra-EU migrants only enjoy at the local and European levels, but not in regional and national elections.

The third and final component of the triad of determinants of migrant claims-making are the collective identities of migrant groups themselves (arrow 4 in Figure 1). This includes migrants’ belonging in a specific ethnic group, their religious affiliation, their identification in terms of a particular "race" (e.g., black), and, of course, their degree of attachment to their country of origin. In some of the literature on transnational communities, and particularly in work on diasporas, we find an almost primordialist conception, which takes such collective identities as fixed and stable attributes, which migrants take with them and insert into the country of settlement. We believe that such identities are to a considerable extent influenced by both other explanatory variables in our model, the receiving state’s integration and citizenship regime (arrow 5), on the one hand, and the conglomerate of homeland influences which we have alluded to above (arrow 6), on the other.

Receiving states may influence migrant identities directly by offering and sponsoring new categories of identification, which were unknown in the country of origin, e.g., the categories of "immigrant", "foreigner", "ethnic minority", or "asylum seeker". At least as important, however, is the possibility that the receiving state’s policies alter the balance among diverse identifications that migrants bring along. Contrary to the sometimes overly one-dimensional conception of migrant identities in the literature, most migrants do not arrive with just one identity, but with several overlapping, cross-cutting and competing ones. Immigrants from Surinam, for instance, may see themselves as Surinamese, but also as Dutch, Hindu, Muslim, Indian, Javanese, Chinese, Christian, Jewish, Creole or black, depending on which ethnic, religious, or racial group in Surinam they belong to, or which of their multiple identities they hold as the most important7. By sponsoring and rewarding some of these migrant identities, and disencouraging others, receiving states may alter the balance among such multiple identities and switch migrants’ primary allegiance from, say, Christian into black, Javanese into Muslim, Creole into Surinamese, etc.

Before we proceed to our analysis of migrant claims-making in Germany, Great Britain and the Netherlands on the basis of this theoretical model, we present in the next section some necessary background on the different approaches to citizenship and migrant integration in these three countries, as well as on the composition of their migrant populations.

Following Brubaker (1992), several authors have emphasized the continuing importance of historically grounded definitions of national identity and citizenship for the integration of minorities of migrant origin (Castles 1995, Freeman 1995, Joppke 1997, 1998, Guiraudon 1998, Favell 1998). Thus Germany’s ‘foreigners politics’ (Ausländerpolitik) was until recently strongly shaped by an ethno-cultural notion of national identity and citizenship, while France deals with its ‘immigrants’ (immigrés) along the lines of the civic ideals of Jacobin republicanism. Among other things, Brubaker’s study shows, that these different national traditions affect naturalization rates among migrants and the ways in which migration and integration appear in the public discourse. In similar vein, other authors have drawn on the social movements literature and have explicitly referred to these institutional frameworks for extending citizenship and the discourses around them as ‘political opportunity structures’ which shape the patterns and levels of migrant and minority mobilisation in different countries (Ireland 1994, Koopmans and Kriesi 1997, Statham 1999, Rosenhek 1999, Koopmans 1999, Bousetta 1997). These ‘political opportunity structures’ define the availability and relative attractiveness of different options for collective action that challenger groups face (see e.g., Koopmans 1999b; Tarrow 1998; McAdam, McCarthy and Zald 1996).

In our own research, we have argued that this general concept can be best translated into a form that is relevant for the claims-making of migrants and ethnic minorities, by focussing on notions of national identity and citizenship and their concrete reflection in policies of minority integration, which we define as the relevant set of opportunity structures for explaining migrant claims-making8. Two basic dimensions of these ‘national models of citizenship’ can be distinguished. First, following Brubaker (1992), national citizenship may be conceived as either an ascriptive, ethno-cultural community of descent and common cultural traditions, ius sangunis, or alternatively, as a civic community defined by adherence to common political values and institutions, and residence on the state territory, ius soli. The second dimension of citizenship relates to the cultural obligations which a country places on defining access to citizenship. Such requirements range from assimilationist to cultural pluralist approaches, which differ in the degree of cultural homogeneity that is demanded by a nation-state for attributing full rights. Here assimilationism is more demanding, it requires that potential new members undergo full conversion to the dominant national culture as the single and unitary focus of identity (at least in the public domain). In contrast, cultural pluralism is more accepting, here the receiving nation recognises, or even facilitates the right of migrants to retain their ethnic or religious difference.

Combining the two citizenship dimensions, we arrive at four ideal-typical national models. Ethno-cultural assimilationism, which until very recently was best approached by Germany, makes access to the political community relatively difficult for migrants of foreign origin, and such possibilities as do exist are tied to the precondition that the candidate assimilates to the culture of the country of residence. Even foreigners who do not want to naturalize are expected to behave as ‘good guests’ and adapt to the cultural requirements of their "host" country. A second model ethno-cultural pluralism, for which Switzerland may be taken as a European example, shares the formal ethno-cultural basis of citizenship with Germany, but does not require migrants to adapt to one clearly circumscribed cultural model. This of course follows from the high level of cultural heterogeneity that characterizes Switzerland as a nation. Nevertheless, there remains a clear hierarchy between the cultures traditionally recognized within the context of Swiss federalism and the newcomer cultures of migrant origin. The third ideal type, civic assimilationism, is best approached by France, which provides for open access to citizenship among other things through ius soli attribution to French-born children, but imposes a unitary cultural mode of conduct for citizens in the public sphere. Thus, the French state does not recognize the existence of ethno-cultural groups as public actors, not even those of native origin such as the Bretons or the Corsicans. Until 1981, the right to form associations on an ethnic or cultural basis was even formally prohibited to migrants. In addition, France strictly adheres to the principle of laicité, which implies a clear-cut separation of religion and State, which severely limits the possibilities for the recognition of religious groups and identities in the public sphere (e.g., in the school system or in the media). Lastly, Britain, Sweden, and the Netherlands are different variations of a fourth type, civic pluralism. Here, as in France, access to the political community for migrants and their descendants is relatively easy through ius soli and/or an active, open naturalization policy. However, such access is not conditional upon assimilation and new citizens are allowed to retain their cultural identities and express them and the interests related to them in the public sphere, including core institutions such as the school system, the military, and the media. Forms of civic pluralism which extend even further than this, and may be labelled ‘multiculturalist’ could even provide for special, formal rights and exemptions from obligations for cultural groups.

Of course, none of the countries mentioned conforms fully to one of the four ideal types, and the migrant/minority politics of each one of them usually constitute varying "mixes" of all four types, with, however, clear emphases in the direction of some ideal-typical positions and not others. Moreover, although historical traditions of national identity and citizenship may affect the legal and discursive boundaries of a country’s minority politics, such boundaries only circumscribe a broad terrain within which important policy shifts are possible, the accumulated weight of which may ultimately push a country into the realm of a quite distinct ideal type. To put at least some flesh on the bones of these schematic characterizations, we now look briefly at some contemporary aspects of the respective citizenship regimes, patterns and forms of immigration and migrant backgrounds, as well as different policy approaches for integration9.

Historically, Germany, Britain, and the Netherlands have gone through broadly comparable waves of immigration. All experienced significantly large-scale foreign immigration due to labor shortages from the 1950s until the economic crisis in the early 1970s, when restrictive immigration controls were implemented and maintained. Many of the migrants in Germany were actively recruited, coming as a result of the ‘guest-worker’ system for importing foreign labor. This produced an official policy that assumed that these ‘guests’ would one day return to their homelands, and so policies for integration were minimal. In contrast, many of the migrants to Britain were already subjects of the British Commonwealth and until 1971 they automatically received equal political and social rights. Since 1965, Race Relations policies in Britain have officially taken measures to combat racism and discrimination and promote social integration, thus acknowledging that political equality has not led to full equal treatment. Between these two poles of immigration experience, significant numbers of migrants came to the Netherlands, both as colonial subjects, especially from Indonesia, Surinam and the Dutch Antilles, and were recruited as ‘guestworkers’, largely from Turkey and Morocco, up until 1974, when labor recruitment programs were shut down. As in the British case, those post-colonial migrants who came, stayed and wished to gain nationality faced few barriers to Dutch citizenship. However, in contrast to the German experience, the ‘guestworkers’ who stayed on faced a more facilitating system of incorporation in the shape of the Dutch ‘pillarization’ model for including ethnic groups in the national polity, as we outline below.

In 1994, the percentage of foreign immigrants relative to total population amounted to 85 people per thousand in Germany, compared to 51 per thousand in the Netherlands, and only 35/1000 in Britain (Table 1). The higher proportion of foreigners relative to nationals in Germany compared to the Netherlands and Britain, illustrates an important outcome of the different citizenship regimes. In Germany, most migrants and their offspring have remained foreigners, as high restrictions were placed on naturalization compared to Britain and the Netherlands. These restrictions in Germany are aptly demonstrated by the fact that in 1997 the number of ‘foreigners’ increased, despite conditions of negative net immigration – the net gain of new ‘foreigners’ were born in Germany of migrant parentage. During the same period, as a result of high numbers of naturalizations, the number of foreigners declined in the Netherlands, in spite of positive net immigration. As a result of these differences, the percentage of foreigners in Britain and the Netherlands strongly underestimates the size of the minority population, as Table 1 makes clear. In fact, Britain, the Netherlands and Germany have broadly similar populations of migrant origin, with the Netherlands surpassing Germany when we include migrants who are Dutch nationals, and Britain coming a close third.

Turning to the countries of origin of the minority populations as displayed in Table 1, we note stark differences between the countries. All have significant numbers of European migrant populations, but Germany’s migrant population is by far the most dominated by Europeans (even if one counts Turkey under Asia as we have done in the table). Today in Germany, the main ‘foreigner’ groups are from Turkey (almost 30% of foreigners), former Yugoslavia (one sixth), Italy, Greece and Poland. In Britain, a large proportion of the ‘minorities’ are British-born, with more than one third coming from the Indian sub-continent and about 12% from the Caribbean. The Netherlands has significant numbers of Turkish migrants in common with Germany, and significant numbers of Caribbean migrants like Britain, and so there are important equivalent groups that can be compared. In addition, the Netherlands have large numbers of people of Moroccan and Indonesian origin, which are hardly found in the two other countries. Lastly, it should be pointed out, that both migrant populations contain religious groups that allow for comparison. Both the large Turkish community in Germany, the Moroccan and Turkish communities in the Netherlands, and the Pakistanis and Bangladeshis in Britain are predominantly Muslims, and make up roughly comparable percentages of the population.

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Table 1 : Composition of the population of immigrant origin in Germany, Great Britain and the Netherlands, in promilles (per thousand) of the total population

Germany(a)

Great Britain(b)

Netherlands(c)

EU countries

22.62

14.05

11.64

Ex-Yugolavia

14.45

0.16

3.45

Other Europe

10.12

1.94

1.30

Total Europe

47.19

16.15

16.39

Turkey

24.99

0.52

17.89

Iran

1.42

0.33

0.43

India

0.42

15.3

0.22

Pakistan

0.47

8.7

0.26

Bangladesh

*

3.0

*

China

0.52

2.9

1.41

Indonesia

0.13

*

15.98

Other Asia(d)

7.06

2.8

2.32

Total Asia

35.01

33.4

38.51

Morocco

0.99

0.17

14.95

Other North Africa(e)

0.67

0.04

0.22

Other Africa

1.99

3.8

2.02

Total Africa

3.65

4.0

17.19

North America

1.50

2.69

0.97

Caribbean

*

9.1

20.97

Other Latin America(f)

1.00

*

0.57

Australia and Oceania

0.12

1.20

0.17

Sum total

89.38

66.70

94.77

Total including persons with acquired citizenship through naturalization or jus soli for all groups(g)

*

74.94

121.76

Foreigners as of 1 January 1994(h)

84.56

35.39

50,83

Muslims(i)

*

16.4-27.3

40.71

Sikhs

*

5.5-9.1

*

Hindus

*

7.3-10.0

4.81

(a)The German data are based on the official statitics regarding the foreign population (Statistisches Bundesamt 2000) and refer to the situation on 31 December 1999. These data do not include naturalized persons of foreign descent for which no cumulative statistics are available. However, due to an until recently very restrictive naturalization regime, the actual number of naturalized foreigners is still very low in Germany. E.g., in the thirtheen-year period between 1980 and 1992 only 230,000 foreigners were naturalized (which amounts to 0.3% of the total German population).

(b)British data are taken from the Official Census data 1991 (Owen 1992, cited Mason 1995) which includes a question on ethnic background and so includes naturalised migrants. From the categories in the Census it is possible to arrive at accurate estimates for the following categories: India, Pakistan, Bangladesh, China, Other Asia, Other Africa (derived from Black African), Caribbean. In addition, to these there are two other categories ‚Black Other‘ and ‚Other Other‘ ethnic groups which capture the remainder of the "ethnic" population. Europeans and North Americans are categorised as ‚Whites‘ in the Census data, and can therefore not be distinguished from native Britons.  As in the case of the Netherlands, we have drawn data for the remaining categories from Eurostat 1994, which, however, only include foreign nationals and exclude naturalized persons from these regions and countries.

(c)Data for people of Turkish, Moroccan, ex-Yugoslav, Carribean, and Indonesian origin, as well as the total figure for the population of migrant origin were taken from Sociaal en Cultureel Planbureau 1999: 28. They include all persons born outside the Netherlands to foreign parents, as well as people born in the Netherlands of which both parents were born outside the Netherlands. Persons born in the Netherlands out of "mixed"marriages have not been included, nor persons born abroad to Dutch parents. The figure for Chinese is based on the same definition and was taken from the Sociaal en Cultureel Planbureau 1997: 19. Figures for all other categories are 1992 figures based Eurostat 1994: 8-9), where necessary in combination with data from the CBS 1996: 52. Because the 1992 figures are relatively old and do not include naturalized persons, the sum of all group figures (next to last table row) is substantially lower than the total population of migrant origin as calculated in SCP data (final table row).

(d)For Germany and the Netherlands, "other Asia" includes (a very small number of) Bangladeshi. For Britain, the figure has been taken from the census category "Other Asian", substracting the Eurostat figures for Turks and Iranians.

(e)For the Netherlands and Britain, excludes (small numbers of) Libyans and Egyptians.

(f)For Germany, "other Latin America" includes (a very small number of) persons from Carribean countries.

(g)The British figure is an estimate based on the total non-white population data from the 1991 Census, adding the Eurostat figures for nationals of other European countries, North America, Australia and New Zealand.

(h)Taken from Lederer 1997: 35-37.

(i)Dutch figures as of 1 January 1995 from CBS 1996: 53. For Britain, figures for the 2001 Census which will also include a question on religion are not available yet. The range estimates for Muslims, Sikhs, and Hindus in the Table are taken from the current literature (Poulter 1998: 197, 238, 282; Rex 1996).

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Major differences between the countries are found in their political strategies for incorporating migrants, which reflect their type of citizenship attribution. Parallel to, and partly as a direct result of their exclusion from formal citizenship, migrants and their organizations – as foreigners – play a marginal role in the German political process. Germany has maintained a policy approach where migrants are excluded from political participation. Apart from the powerless and marginal foreigners’ councils (Ausländerbeiräte) on the local level, foreigners in Germany have no institutionalized channels of access to the political process. The German state does not provide the kind of facilitation to migrant organizations that many of their British and Dutch counterparts receive. There is no institutional focus for minority claims in the form of an official minority, racial equality, or anti-discrimination politics, which might legitimate migrant demands and identify responsible authorities for their implementation. The official mantra that ‘Germany is not an immigration country’, which German governments until very recently adhered to, has therefore had real consequences for the opportunities for minority claims-making.

In contrast to Germany, migrant organization and political participation — as ethnic or racial minorities — is facilitated by the British state, particularly at the local level. In Britain, a state-sponsored ‘race relations’ industry has emerged backed by anti-discrimination legislation and the authority of the Commission for Racial Equality and local bodies to report and advise on practices for ensuring equal treatment, in particular in the labor market. It is worth emphasizing, that ‘race’ is a category that British political élites adopted when attempting to address the disadvantage of minority populations caused by discrimination. This ‘racialization’ of policy measures in part reflected the fear of political élites that British ‘race riots’ might escalate to the crisis point of those experienced in the United States. An outcome of this is that British policies were more tailored to the integration of Afro-Caribbeans under the generic umbrella term ‘black’, than the relatively later inflows of migrants from the Indian sub-continent, and in particular Pakistan (Rex 1991). Race relations politics has been extended to Indians, Pakistanis and Bangladeshis under the generic term ‘Asian’, which implies that groups with a self-identification that is non-racial, the prime example being groups with a Muslim identity, have been served relatively less well by the institutional apparatus (Modood, 1997). Another point worth making about the British case, is that the constituency-based electoral system has provided the large concentrations of minority communities in specific towns and regions with a considerable resource-base of voting power for influencing individual Members of Parliament, and has in turn led political parties to take up issues relating to ethnic minorities. At the local level of politics, minorities have also made a considerable impact in specific regions (e.g., Solomos and Back 1995).

Lastly, turning to our third case, the Netherlands recognized relatively early that many migrants would remain, and reacted through the inclusive Minderhedennota of 1983, based on the principle that ‘Dutch society will permanently have a multicultural character’ (for further detail on the Dutch case, see Duyvené de Wit and Koopmans 2001). In line with the Dutch tradition of pillarization, the government’s policies provided for a large degree of autonomy for ‘ethnic minorities’ in the cultural sphere, incorporated minority elites into the policy process through subsidization of representative organizations and their inclusion in the policy deliberation and implementation processes. In the Netherlands, and in stark contrast to the German situation, the state even opened up civil service positions and local voting rights to foreign residents. In addition, Dutch cultural pluralism did not provide the ‘racialised’ straightjacket for minority identities of the British variant. Rather than requiring resident former colonial subjects to become racial minorities to achieve rights, the Dutch view integration as best accomplished through confident subcultures, thus making the preservation of minority cultures an essential part of incorporation. Although Dutch minority policy moved away from this idealist undiluted multiculturalism of the 1980s, and toward a more British-style focus on socio-economic parity in the 1990s, when the realism set in that maintaining group diversity could also mean structuring disadvantage for those groups, it still retains important distinctive characteristics. The continued relevance of the institutional inheritance of pillarization still makes the Netherlands unrivalled by Britain in the range of cultural opportunities that are provided. While the issue of Muslim schools is highly contested in Britain, with the first non-primary school being given state funding in 2001, there have already been dozens of state-funded Muslim and Hindu schools in the Netherlands for some years. Just as the ‘old’ Christian and Protestant pillars had their own state-sponsored semi-autonomous institutions in education, health, welfare and the public media, such rights cannot be denied to the new cultural and religious minorities of migrant communities. This Dutch multiculturalism avant la lettre adding minorities and foreigners on as another ‘pillar in the polder’, is important to our current discussion, as the Dutch cultural pluralist approach, provided incentives for migrants — both former guestworkers and resident colonial subjects — to keep their heads, at least through cultural identification, in both the homeland and receiving societies, whilst at the same time gaining a significant degree of access to political and social rights. This makes the Dutch trajectory different from Germany, where the political exclusion of former guestworkers under the banner ‘Germany is not a country of immigration’ left migrants looking homewards, and different from Britain where the ‘racialisation’ of cultural pluralism, shaped postcolonial migrants into inward-looking British racial minorities.

To investigate the public claims-making of migrants and ethnic minorities in Germany, Britain and the Netherlands, we use data drawn from content analyses of daily newspapers in the three countries. In contrast to many media content analyses, we are not primarily interested in the way in which the media frame events. On the contrary, our focus is on the news coverage of mobilization, public statements and other forms of claims-making by non-media actors. Taking a cue from ‘protest event analysis’ in the study of social movements (Tarrow 1989; Olzak 1989; Rucht, Koopmans, and Neidhardt 1998), our units of analysis are not articles, but individual instances of claims-making. Instances of claims-making have been included irrespective of their form, and range from violent attacks on other groups, public demonstrations and legal action, to public statements.

Acts were included in the data if they involved demands, criticisms, or proposals related to the regulation or evaluation of immigration, minority integration, or xenophobia. Because of our special interest in minority claims-making, we included acts by resident ethnic minorities even if they were not related to these issues — provided, of course, that they involved some political claim — which in particular allowed us to include the claims-making of migrants related to the politics of their homelands11. Regarding territorial criteria we included all acts in Britain12, the Netherlands, and Germany, respectively, even if they were addressed to foreign or supranational authorities, or made by organizations (primarily) based outside our countries of study. All these types of acts were considered to be claims in the British, Dutch or German public spheres.

There are obviously limitations to our data. First, the data-set excludes claims-making outside the public sphere (e.g., lobbying), as well as claims-making in partial public spheres (e.g., claims directed at school boards by parents, or purely local issues). However, it should be pointed out that once such claims become controversial they, too, tend to eventually be report