Is there (still) an East-West divide in the conception of citizenship in Europe? - Constantin Iordachi: How (not) to think about historical regions?

Constantin Iordachi: How (not) to think about historical regions?

The question posed to this citizenship forum, "Is there (still) an East-West divide in the conception of citizenship in Europe?" is an exercise in comparative history. In order to provide a theoretically minded and empirically informed answer to this question, one has to analyze historical case studies of citizenship in "East" and "West" under a common comparative framework. How can such a comparative framework be built? What would it entail? Methodologically, any comparative framework has to specify the following elements: the aim of the comparison; the working hypothesis to be tested; the methods employed to this end; the units of comparisons; and the diachronic or synchronic perspective to be employed.

Although not stated explicitly, the aim of the comparison can be easily inferred from the research question posed to the forum, namely to identify the similarities and differences between conceptions of citizenship in Eastern and Western Europe in order to establish them either as identical or as distinct types. This appears to be one of Professor André Liebich's main research aims, set both in his introduction to the volume of Citizenship Policies in the New Europe (2007; 2nd ed: 2009), and in his kickoff contribution to this forum. Professor Liebich argues that conceptions of citizenship "differ widely between Western and East Central Europe" due to "a number of historical and contemporary reasons." Historically, East Central Europe exhibits the example of a "peripheral or lagging development" as compared to the paradigmatic Western European model of development, given the fact that it "missed out at the beginning of the modern era on the turn towards an Atlantic-centred world-system." To their divergent historical developments, Prof. Liebich adds other factors which differentiate East Central European states from their more advanced Western counterparts, namely their small size, the fragility of their statehood, and mostly their traditional "isolation," which further deepened during the communist period. Due to this complex combination of factors, the East-Central European conception of citizenship currently differs from the Western one in its value system. These differences in values are most manifest in: 1) the role of played by ethnicity in determining attitudes towards citizenship in East Central Europe; and, most importantly, in 2) the modes of acquisition of citizenship at birth, where "we see a clear and dramatic difference between the old and the new EU members" (my emphasis): ius sanguinis is the only way of acquiring nationality in the new EU member countries located in East Central Europe, while in eight of the old EU states second or third generations born in the country of non-citizen parents are eligible for citizenship on the basis of the ius soli principle. Prof. Liebich concludes that the East Central European conception of citizenship exhibits a case of incomplete modernization. It is to be expected that, eventually, East Central Europe will catch up with the West and will embrace the Western conception of citizenship. Yet, given the avatars of its historical development and its long-term isolation, "the gulf between conceptions of citizenship in East and West will not be bridged soon."

Prof. Liebich's main argument is in line with a long and established tradition of thinking about Eastern Europe as an example of a "deviant" development, substantiated by teleological typologies on modernization, nationalism, or time-zones of nation and state-building in Europe. Although these typologies are very diverse and often divergent in their definition of “East” and “West,” they all converge in contrasting the developed “West” to an underdeveloped “East” (referring to Central, South Eastern and Eastern Europe), the development of the former being portrayed mainly in positive terms, while that of the latter in negative ones. Most of these typologies were produced during the Cold War, when—under the strong impression of the political cleavage between the “First” and the “Second” worlds—Western historians advocated the idea of a wide divergence in the historical development of the two halves of the continent. Their perception was to a great extent shaped by disillusioned local or émigré Eastern historians who advocated the idea of a “deviationist,” “mutant” or even "pathological" historical development of Eastern Europe (for a relevant example, see István Bibó's 1946 essay, “The Distress of East European Small States,” which provides the basis of Prof. Liebich's interpretation of East Central Europe). While adopting the core of their argument, Prof. Liebich introduces two new elements to these Cold War typologies: first, he replaces the traditional analytical category of Eastern Europe with the more recent geo-political term "East Central Europe;" and second, he extends existing typologies on industrialization, modernization, and nation- and state-building in various historical regions of Europe to the realm of citizenship, as well.

In the following, I shall depart from this line of interpretation. I shall argue that, while the question posed to this form can potentially constitute a valid research aim, it nevertheless suffers from a major analytical flaw: the units of comparison are not defined in the process of research but appear to be pre-given, based on the assumption that conceptions of citizenship are an inherent product of, and thus specific to, historical regions in Europe. I shall attempt to refute the idea of a clear-cut dichotomy or "gulf" between a “Western type” of citizenship and an “Eastern type” and to question the explanatory power of generic conceptions of citizenship to describe the concrete historical experience of entire regions, understood as homogeneous, monolithic constructs (for an in-depth critique of such views with reference to the Balkans, see Iordachi 2006). Contesting the heuristic utility of such normative concepts as "East" and "West," I propose instead a different, integrated comparative perspective for approaching the history of modern Europe which does not take Western Europe as a normative measuring stick but instead accounts for a plurality of historical experiences which constitute our common European identities.


1, First, I argue that "East" and "West" are normative and not analytical categories, and cannot serve as valid units of analysis of citizenship policies in Europe. In my view, concepts of historical regions are no more than analytical constructions devised for heuristic purposes; as abstract concepts, they do not reflect historical reality per se, but are (ever-changing) attempts at endowing geography with historical and cultural meaning, reflecting “essentially contested” geopolitical conventions prevalent at a certain point in time. The concepts of East and West are a case in point. As Larry Wolf has pertinently pointed out (1995), Eastern and Western Europe are relatively new and inter-related categories on our mental maps. From the eighteenth century onward, the traditional North vs. South symbolic geographical line which was taken to separate "Barbarity" from "Civilization" was reformulated as an East-West divide. Responsible for this new continental "mental map" were les philosophers during the Enlightenment period, who articulated a new, hegemonic discourse on the Eastern European otherness, as a necessary ingredient in the construction of a modern Western identity (for related debates over symbolic geographies, see Said 1979 on "Orientalism;" Carrier 1995 on “Occidentalism”; and Todorova 1997 on the Balkans ). The rich and highly disputed history of the concept of Central Europe is another case in point for the social construction of concepts of historical regions and their political implications. The concept of Central Europe was born after, and was thus dependent on, the concepts of Eastern and Western Europe, being conceived as a buffer zone in-between those two major geo-political categories. During the last two centuries, one can identify a great number of rival definitions of Central Europe: from the Habsburg vision of Central Europe of the eighteenth and nineteenth centuries, the Hungarian Kárpát-medence (Carpathian basin), the German Mitteleuropa on the eve of World War One, the French dominated Europe Centrale of the interwar period, to the purge of the concept of Central Europe from the Cold War political vocabulary under Soviet hegemony and its revival in mid-1980s in the work of anti-communist émigré intellectuals and dissidents (Janowsky, Iordachi, Trencsényi 2005). The term East Central Europe, employed by Prof. Liebich, is even more recent, being currently employed as a convenient shortcut used to designate the group of states which joined the EU in 2004, from the three Baltic states (Estonia, Latvia, Lithuania), to the four Visegrád countries (Poland, the Czech Republic, Slovakia and Hungary), and Slovenia in former Yugoslavia (supplemented more recently by the new EU members, Romania and Bulgaria). As such, the term does not refer to a compact historical region per se, but cuts across other, more established concepts of historical regions, such as the older tripartite division between Central, Southeastern, and Eastern Europe. Significantly, Germany is left out of the concept of East Central Europe, irrespective of its traditional historical ties with Central Europe or the communist legacy of its Eastern part, the former GDR. So is Greece, which, although geographically in the Balkans, is symbolically excluded from its immediate regional context and integrated in the "political West" on the count that it joined the EC/EU as early as 1981.

One encounters similar problems in defining “the West.” What are the borders of this geo-political category? Do they incorporate all countries which are located geographically in Western Europe, including here Spain, Portugal and Ireland? Or only those who undertook the “dual” industrial and political revolution at similar times, thus maybe restricting our sample to France, England, and the Benelux countries (Belgium, the Netherlands, and Luxembourg)? Given their history of "late" state formation, relatively late industrialization and strong fascist regimes in the interwar period, what is the symbolic position of Germany and Italy? Are they part of Central Europe or of Western Europe? Would the concept of the West, as employed by Prof. Liebich, refer to the fifteen “old” EU members, thus including Greece and Austria but excluding Switzerland, as a counterpart of the ten new member states, symbolically located in East Central Europe? Or would the category of the (political) West, refer to all those countries which are allegedly characterized by a set of common political values, including here Canada and the US?

Given the normative political connotations of apparently “neutral” regional geographical denominations, terms such as Western, East Central or Eastern Europe cannot be employed without ample methodological clarifications. At first sight, their usage as units of comparison seem to be fully justified by the well established academic tradition of “area studies,” as reinforced by the scholarship elaborated during/in view of the Cold War: on the one hand the former "Soviet camp" made up of the satellite socialist states; on the other hand, the "political West," which developed common economic and security organizations since 1945. At close scrutiny, however, it becomes apparent that these heterogeneous, ad-hoc, and highly politicized geopolitical constructs cannot constitute valid units of analyzing conceptions of citizenship.


2. Second, what is the analytical utility of these concepts of historical regions for the history of citizenship in Europe? Are there distinct Eastern versus Western "conceptions of citizenship"? The answer to this question depends on two main points: the definition given to "conceptions of citizenship" and the selection of the set of features such conceptions of citizenship need to display in order to qualify as distinct types. The first point occasions a methodological discussion about the relationship between citizenship legislation and more general conceptions of citizenship. I, for one, treat citizenship as an "essentially contested concept" whose meaning is never stable but shifts over time as a function of the fluid understanding/positions taken by various actors during the political process. On this basis, I do not equate legislation on citizenship or legal policies of naturalization with “fixed” and “internally unified” conceptions of citizenship, but I take the former as complex outcomes of political negotiations at various levels. But even if we agreed that there indeed exist coherent and homogeneous national or even regional conceptions of citizenship at work in contemporary Europe, the selection of their main representative features remains a difficult exercise. Prof. Liebich singles out two major features which differentiate Eastern and Western conceptions on citizenship: 1) the recent legislation on kin-minorities abroad adopted in East Central Europe; and 2) techniques for ascribing citizenship at birth. Are these valid criteria to differentiate between regional conceptions of citizenship? I believe not.

The first criterion does not stand to close scrutiny: as other respondents to this forum have also pertinently pointed out, legislation on kin-minorities abroad is not specific to East Central Europe, but to other non-Eastern countries as well (Spain, Portugal, Greece, Italy, Ireland, etc.). To take this as a mark of an East Central European conception of citizenship would be thus misleading. The concerted wave of recent laws on kin-minorities abroad adopted in East Central Europe can be historically explained by the fact that, during communist regimes, national policies for the protection of minorities abroad were largely suppressed under the terms of the pax Sovietica; it was only after the collapse of communism that these countries could resume their national policies, in various forms.

The second criterion of differentiation between the Western and East Central European conceptions of citizenship is found in the role assigned to the ius soli and ius sanguinis principles in ascribing citizenship at birth in the two regions. This argument, too, cannot stand up to close scrutiny, due to a number of factors. First, and most importantly, although ius soli and ius sanguinis are often taken--uncritically, I believe--to provide the foundations of distinct models of political communities, in fact these rules are no more than techniques of ascribing citizenship at birth; as such, these legal principles do not reflect, in themselves, conceptions of citizenship. In fact, these techniques tell us nothing about the political value systems or visions of citizenship at work in certain countries or regions: various historical examples show us that they can be equally built into liberal as well as in illiberal citizenship regimes. Second, although taken by Prof. Liebich as a symbolic border between East-Central and Western conceptions of citizenship, the line of differentiation between ius soli and ius sanguinis policies of citizenship is in fact not geographical but follows from established legal traditions. More precisely, one can distinguish between, on the one hand, typical countries of immigration such as the US and Great Britain, which follow the Anglo-Saxon legal tradition and grant citizenship to all inhabitants born in the country on the basis of the ius soli principle, and, on the other hand, most European countries, which ascribe citizenship at birth to descendents of citizens according to the principle of ius sanguinis. Evidently, the dividing line between these two, Anglo-Saxon and continental, legal traditions is not congruent to the East vs. West geographical distinction: First, it cuts across the allegedly homogeneous analytical category of the "West," along the English Channel. Second, most Western and East Central European countries belong in fact to the same continental tradition of ascribing citizenship at birth iure sanguinis. The difference within this continental tradition is that some countries rely exclusively on the ius sanguinis principle in ascribing citizenship at birth, with the total exclusion of the ius soli principle, such as in Germany prior to 2000; while other countries, such as France, supplement the principle of ius sanguinis with the principle of ius soli ascription of citizenship at birth to foreigners born in the country. Yet, this internal difference within the continental tradition is not absolute: although, as Professor Liebich notes, the ius soli principle is lacking in policies of ascribing citizenship at birth in numerous East Central European countries, it is nevertheless present, in various forms, in policies of naturalization of foreigners born in the country. Let me employ the example of the Romanian legislation, which is closer to my research interest. The 1991 law applied citizenship at birth to descendents of at least one Romanian citizen, according to the ius sanguinis principle. Indeed, the ius soli principle has no bearing upon ascribing citizenship at birth. Yet, in its provisions concerning naturalization, the law grants access to naturalization at adulthood to foreigners born in the country who continue to live there at the time of their request. True, the naturalization of foreigners born in the country is currently not automatic (as it used to be until 1952), but is subject to the standard procedure for naturalization (apart from the general residence period required for ordinary naturalization). But we should note that even France, the paramount example of an inclusive combination of ius sanguinis and ius soli policies of ascribing citizenship at birth in continental Europe, has recently discontinued the automatic access to citizenship at birth of foreigners born in the country (see the 1993 citizenship reform act which, instead of granting naturalization, required foreigners born in the country to request French nationality at adulthood). This requirement was abrogated in 1998, but under current regulations children born in France of foreign parents become French citizens only upon reaching adulthood). Overall, while differences in policies of ascribing citizenship within the European continental tradition still exist, they do not appear to be "clear and dramatic". On the contrary, as the recent amendments to citizenship laws in France and Germany referred to above show, there is a process of convergence. Most importantly, although procedures differ, the consequences of the policy of ius soli naturalization of foreigners born in the country tend in practice to be fairly close to policies based on a combination of ius soli and ius sanguinis ascription at birth: both result in the naturalization of the first or second generation foreigners born in the country.

It thus becomes obvious that, even if one agrees on feasible definitions of "East" and "West" (an issue which, given the methodological challenges spelled above, is highly problematic), one cannot identify two distinct Eastern versus Western conceptions of citizenship. Yet, what are the implications of this statement? Does this mean that historical regions are irrelevant units of analysis? Should historical regions be abandoned as units of comparison? Certainly not; I do share the view that historical regions can serve as privileged angles through which to approach the history of certain geographical spaces and as useful heuristic devices for tackling certain research topics with an obvious regional significance. While arguing for the relevance of historical regions for research, I nevertheless plead against rigid or “totalizing” definitions of such regions that would cut across various historical periods or would disregard factors of internal differentiation. Lumping together East Central European countries makes sense only on well-defined and issue-oriented research topics, e.g. in view of their common communist legacy and their post-communist transformation. While this perspective may justify their common treatment, similarities should not be uncritically extended to all their historical or contemporary features. To do so would be to impose homogeneity upon an extremely heterogeneous category.

It is fairly easy, I believe, to discard those historical or conjectural features/criteria which are arbitrarily taken to characterize all East Central European states, such as their smallness, fragility, and isolation: First, although there has indeed been a process of continuous political fragmentation of the region in small independent political units, East Central European countries are not invariably small (just as Western European countries are not without exception large): Poland, Ukraine and Romania are large to medium-size countries. Complete statistics on population and territorial size would certainly show a very variegated geographical ranking. Second, East Central European countries are not necessarily fragile; this criterion is, in itself, ambiguous and begs for a more precise definition: but if we refer to discontinuous statehood as an example of fragility, then modern Romania--to give but one example--exhibits the case of uninterrupted state continuity from its very creation, in 1859, just like the two "Western" states established at similar times, Italy and Germany. From this point of view, to place Romania in the East and Italy and Germany in the West would not be justified; it is more rewarding analytically to treat them together as part of the same time-zone of nation and state-building, as surprising as that would seem at first sight. Third, East Central European states were never fully isolated from European trends, not even during the communist regime, the two rival political systems being in fact largely interdependent and contaminated by mutual influences. In the realm of citizenship, legal differences between the two blocks were to a certain extent mediated by the UN (see its conventions on citizenship), the 1973 Conference on Security and Co-operation in Europe (CSCE), and the 1975 Helsinki agreement.

In historical terms, the development of East-Central European countries has never been unitary: it fact, in the modern period, they have been shaped by at least three distinct imperial legacies (Habsburg, Ottoman, Tsarist) and by various post-imperial waves of Western style modernization, informed by different models and combined with local traditions and innovations. In economic terms, these countries were not necessarily backward; see the industrialization of Bohemia or Silesia (currently part of Poland), or the near take-off towards industrialization of Austria-Hungary at the turn of the century. True, after 1945 these countries were subject to a forceful process of Sovietization; yet that process was neither uniform nor monolithic but was made up of a set of multifaceted, large-scale institutional and ideological transfers, characterized by multiple "takeovers" in various fields. Consequently, despite decades of forced Sovietization, East Central European countries are not fully alike but exhibit great historical differences in the modern juridical and political models they have adopted, in the main features of their socialist regimes, and their paths to post-communist transformation.

By the same token, one can reverse the question and deconstruct the Western model of development, as well. Is there such a unified historical model? What are its main features? Which countries would embody that model most closely? Do France and England, to take two of the core countries generally referred to as "the West," exhibit a similar historical development that would translate into a common conception of citizenship? "If capitalism is of one piece, why is the working class it called into life so disparate?" asked Aristide Zolberg in a famous article in which he urged historians to go "beyond the 'exceptionalist tradition' and its mirror image, 'the end of ideology approach'" (1999: 401). The question can be extended to other reasearch aspects, as well. Discourses on the "uniqueness of the West" thus appear as an excercise in epitomizing or typifying “the West”, an exercise James Carrier called “Occidentalism” and which he succinctly defined as “stylized images of the West” elaborated by Western scholars in their encounters with non-Western cultures (1995).
Ultimately, even if one can prove a quasi-identical historical development of East Central European countries, on the one hand, and Western European countries, on the other, what relevance would that have for delineating regional conceptions of citizenship? Is the historical development of citizenship in various countries in East and West a direct outcome of the level of economic development of the particular historical region they belong to? Or is it a function of wider factors that have to do with their legal and political systems and, as such, exhibit a certain autonomy from the socio-economic sphere? In view of these objections, to lump all countries in one region together in Western or East-Central European conceptions of citizenship is both methodologically problematic and factually inaccurate.

On a more general level, I argue that, in order to understand citizenship legislation in Europe in all its diversity and complexity, we must abandon “teleological” typologies based on “normative” ideological premises, which regard non-Western countries as would-be carbon copies of the West and deny them historical agency and institutional creativity. Rejecting master narratives on European history which equate the history of the continent with the historical experience of Western Europe, I plead instead for an integrative European perspective that incorporates case studies of citizenship in Europe within a common but non-normative and non-teleological methodological framework. Informed by recent theoretical and methodological perspectives on the “shared” or “connected” history of Europe, such an integrative approach would be able to uncover the mutual interdependence among case studies of citizenship in Europe and thus undermine the prevailing tendency to essentialize the experience of European historical regions such as “the West” or the “East”. It would relativize Western “exceptionalism” and Eastern “distinctiveness” in favor of relational and transnational approaches. I, for one, am at work on such a project.

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