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Is there (still) an East-West divide in the conception of citizenship in Europe?


Kickoff contribution by André Liebich, Graduate Institute of International and Development Studies

August 28, 2009

All the new EU members in East Central Europe have revised their nationality laws since the fall of communism. Most countries have adopted new legislation, sometimes more than once. The one exception, Poland, has reinterpreted crucial aspects of its existing nationality law in so radical a way as to amount to new legislation. All these countries are mindful of the Council of Europe's latest Convention on Nationality (1997). Indeed, all these countries now share a common European citizenship with their Western neighbours.

But the question put in this forum goes beyond the question of nationality laws to inquire about conceptions of citizenship. It is such conceptions that will affect future revisions and interpretations of nationality laws and, most crucially, their application. They will also determine how people live their nationality and how they incorporate or exclude others from sharing a common citizenship. I would argue that these conceptions differ widely between Western and East Central Europe for a number of historical and contemporary reasons.

The historic differences between the two parts of Europe have been described by scholars (for example, Berend 1986, Chirot 1989, Janos 1989) in terms of peripheral or lagging development. Elsewhere, I have emphasized the recent establishment of the existing East Central European states and the resultant fragility of their statehood as a factor of differentiation (Liebich 2007). In the context of this forum, I would underscore the historic isolation of East Central Europe. I am not thinking only of the "Iron Curtain" that separated the Soviet Bloc from the rest of Europe in the second half of the twentieth century. I am referring also to the fact that this area "missed out" at the beginning of the modern era on the turn towards an Atlantic-centred world-system. Some of the transformations that originated in Western Europe, such as capitalism and the Industrial Revolution, came to East Central Europe well after their inception in the West. Other innovations, such as the modern nation state, were only adopted but also adapted at a later date. Still others, notably overseas expansion, never marked this area. A measure of this isolation is that none of the official languages of the new EU members has official currency in another country, as is the case for all the old EU members' languages (with the exception of Finnish).

This isolation from many defining currents of present-day Western Europe explains certain striking differences in value systems. Intuitive or anecdotal findings in this respect are confirmed by empirical studies. A recent enquiry (Best 2009) puts a number of citizenship-related propositions to elite and general respondents in ten old EU countries and seven new EU members. In response to the statement, "To be a [national] it is important to have [national] parents," the first five respondents who answer affirmatively are all new EU members (Poland, Bulgaria, Estonia, Czech Republic, Hungary) as is the seventh (Lithuania). In reply to the statement, "To be a [national] it is important to be born in [country]," four of the first five affirmative respondents are new EU members (Estonia, Poland, Bulgaria, Czech Republic). Finally, "To be a [national] it is important to be a Christian," five of the top seven respondents are new EU members (Poland, Bulgaria, Lithuania, Estonia). These findings may be compared to those of another study (Fuchs and Klingemann 2006) which looks at twenty-seven countries, including all ten post-communist EU members and four old EU states (Sweden, Finland, Spain and West Germany, excluding the ex-DDR). The study concludes that the level of "trust in others" is almost twice as high (43% vs. 22%) in the old EU countries selected compared to the new EU ones. The level of "ethic tolerance," meaning acceptance of homosexuality, prostitution, abortion and divorce, is close to three times higher in these old EU states than in the new EU countries (32% vs. 12%).

Isolation may be even more important than ethnicity in determining attitudes towards citizenship. The new EU members routinely make citizenship acquisition easier for co-ethnics and their descendants but so do four old EU members (Ireland, Italy, Germany, Greece) and two others facilitate citizenship for ex-colonial populations (Spain and Portugal). It is only when we compare modes of acquisition at birth that we see a clear and dramatic difference between the old and the new EU members. In seven of the fifteen old EU states, ius sanguinis is the only way of acquiring nationality; this is the case for all the new EU states (with exceptions in both types of states for children born stateless or foundlings). In eight of the old EU states, however, citizenship on the basis of ius soli may be acquired for the second or third generation born in the country of non-citizen parents (Bauböck 2006). As far as I can determine, there are no corresponding provisions in the new EU states.

This discrepancy must be seen in the light of the huge differential in the number of immigrants between the two parts of Europe. If one discounts the extreme case in Western Europe (Luxemburg with 40% foreign residents) and the exceptional situation of Estonia and Latvia in Eastern Europe, with their numerous non-naturalized russophones (17% and 19% of the country's population respectively) one finds that some 6% of the old EU consists of residents with foreign citizenship. The corresponding figure in the ten EU post communist countries is barely 1% (eurostat cited in Liebich 2008). Similarly, the foreign born represent some 11% of the population in the old EU 15 and only 6,5% of the eight post communist states that adhered to the EU in 2004; if one discounts for Latvia (19,2%) and Estonia (15,2%) where the foreign-born are ex-Soviets and for Slovenia (8,5%) where the foreign born are ex-Yugoslavs, only 3% of these post-communist populations is effectively foreign-born (Migration Information Source 2005).

Comparative studies have shown (counter-intuitively perhaps) that resistance to immigrants is stronger in Eastern European countries where they are fewer than in Western European countries where they are more numerous (Coenders et al 2004). In response to the question, "would you object to a foreign neighbour?" affirmative answers in the old EU run to less than 20% of the population (and less than 10% in Sweden, the Netherlands and Portugal) except in Italy and Belgium where they are in the 20% to 30% bracket. In the nine post-communist EU countries surveyed (Hungary was omitted), only in two countries, Latvia (!) and Slovenia, did fewer than 20% of the respondents answer affirmatively, four were in the 20% to 30% bracket (Poland, Czech Republic, Lithuania, Estonia) and in three (Slovakia, Romania, Bulgaria) answers ranged between 30% and 40%. The responses in the Russian Federation were closer to those of Western Europe than to those of the new EU members (Halman et al 2005). Inwardness, as much as suspicion, would seem to explain such results. New EU citizens are only one-third as favourable to the open European labour market as are citizens of the old EU states (10% vs 33%), even though it is new Europeans who are set to benefit most from such openness. Whereas more than 60% of Europeans in the old EU states are "proud to be European citizens," this is the case for only 42% of new Europeans. Not even the highest response rate here (59% for Hungary) attains the old EU average (Thomassen and Bäck 2008).

If the strangeness of the outside world has been a fundamental reality to the new EU states in the past, one can see that this is rapidly changing with highly developed communication, travel, short term emigration and repatriation. Most significantly from our point of view, the new EU countries are becoming, for the first time in recent history, countries of immigration rather than only of emigration. Reliable figures are hard to find, if only because much of the immigration is illegal, but the anecdotal evidence is abundant. Workers from the former Soviet Union flock to the shadow economies of East Central Europe and hope to blend into the population. Legal or illegal Chinese and Vietnamese immigrants are more visible, whether in low-skilled jobs or in the economic niches they have established. Some of these immigrants may move home or move West, but many will stay and the question of their citizenship will inevitably come to the fore.

On the basis of what we have seen, the new EU states will not find it easy to amend their citizenship laws and practices in such a way as to integrate these new arrivals. The new EU states see their national community as composed of those born in their country, of parents who were also born there. These states have made allowance for gathering in members of their own diasporas who choose to return home or to reassert their ties to their homeland. They will need to fundamentally rethink their conception of community to formally incorporate newcomers or the children of newcomers with no blood ties or historic connections to the country. True, such a reformulation of citizenship is nowhere easy. Germany, the West European country with the closest ties to the new EU members, famously refused to see itself as a country of immigration until a decade or so ago. The pressure of time and numbers has forced it to reconsider. Ex-imperial EU members have transformed colonial intercourse into national integration, whether of a "republican" sort, as in France, or of a "multicultural" variety, as in Britain or the Netherlands. The new EU members have no such experience to fall back upon and they will not be given the time to adjust to new realities. It is unlikely that in the near future they will amend their nationality laws to facilitate the naturalisation of unrelated immigrants or to confer citizenship automatically upon the offspring of these immigrants. The gulf between conception of citizenship in East and West will not be bridged soon.


- Bauböck (2006)
Rainer Bauböck, "The Acquisition and Loss of Nationality in 15 EU States. Results of the Comparative Project NATAC," IMISCOE Policy Brief no. 2, 2006.


consulted 7 August 2009

- Berend (1986)
Ivan T. Berend, "The Historical Evolution of Eastern Europe as a Region," International Organization 40:2 (Spring 196) pp. 329-346.

- Best (2009)
Heinrich Best, "History Matters: Dimensions and Determinants of National Identities among European Populations and Elites," Europe-Asia Studies 61:6 (August 2009) pp. 921-941.

- Chirot (1989)
The Origins of Backwardness in Eastern Europe. Economics and Politics from the Middle Ages until the Early Twentieth Century, edited by Daniel Chirot. Berkeley: University of California Press, 1989.

- Coenders et al (2004)
Marcel Coenders, Mérove Gijsberts and Peer Scheepers, "Resistance to the Presence of Immigrants and Refugees in 22 Countries," in Nationalism and Exclusion of Migrants: Cross-National Comparisons, , edited by Mérove Gijsberts, Louk Hagendoorn, and Peer Scheepers. Aldershot: Ashgate, 2004, pp. 97-120.

- Fuchs and Klingemann (2006)
Dieter Fuchs and Hans-Dieter Klingemann, "Democratic Communities in Europe: A Comparison between East and West," in Democracy and Political Culture in Eastern Europe, edited by Hans-Dieter Klingemann, Dieter Fuchs and Jan Zielonka. New York: Routledge, 2006, pp. 25-66.

- Halman et al (2005)
Atlas of European Values, edited by Loek Halman, Ruud Luijkx and Marga van Zundert, Leiden: Brill.

- Janos (1989)
Andrew C. Janos, "The Politics of Backwardness in Continental Europe," World Politics 41:3 (1989) pp. 325-358.

- Liebich (2007)
Andre Liebich, "Introduction: Altneuländer or the Vicissitudes of Citizenship in the New EU States," in Citizenship Policies in the New Europe, edited by Rainer Bauböck, Bernhard Perchinig, & Wiebke Sievers, Amsterdam: Amsterdam University Press, pp. 17-40.

- Liebich (2008)
Andre Liebich, "How Different is the 'New Europe'? Perspectives on States and Minorities," CEU Political Science Journal 3:3 (September 2008) pp. 269-292. Figures for 2006 from


, consulted 7 June 2008,

- Migration Information Source 2005
[based on OECD Database, UN Migration Database (2005),] Migration Policy Institute,

http://migrationinformation.org/charts/ ... -jun06.cfm

consulted 3 August 2009.

- Thomassen and Bäck (2008)
Jacques Thomassen and Hanna Bäck, European Citizenship and Identity after Enlargement, EUI Working Papers SPS 2008/2