Migratory policies and political cultures in Europe: Is there something new?

Demonstration of migrants "sans papiers" in Paris
Teaser Bild Untertitel
A demonstration in Paris where many illegal immigrants work in various industries without work permits or benefits (2008)


by Umberto Melotti

Immigration and political cultures in France, Britain and Germany

The Italian case
The communitarisation of the European migration policies


This paper discusses the relationships between the migratory policies of the EU countries with more experience of immigration and their national political cultures. It focuses on France, Germany and the United Kingdom. Then it looks briefly at Italy, a relatively new country of immigration, which, with almost 4,000,000 immigrants, has become the fourth country of immigration in Europe and the first in the Mediterranean basin. In its final part it highlights the process of “communitarisation” of the immigration policies of EU countries, which has already entailed a certain convergence of their migratory policies.


In the last decade there was a considerable change in the migration policies of the main European countries of immigration. This was due, to a large extent, to the process of globalisation, which, among other things, has entailed a change in migration itself and in the political cultures of the countries of immigration. But it was also due to the development of the process of Europeanisation, which has exerted an important influence on the migration policies of the EU member States.

To point out this change, it is useful to assess the relationships between the migration policies of the main European countries of immigration and their political cultures (where “political culture”, in contrast with less comprehensive views, defines the specific way State, people and nation are conceived, ethnicity, nationality and citizenship are perceived, and citizenship rights and duties are recognized or attributed to native and non-native people).

In fact, in any country, political culture has exerted an important influence on both aspects of the migration policies: the “entry policies”, i.e. the norms and practices concerning the admission of foreigners, and the “policies for the immigrants”, i.e. the norms and practices meant to govern their presence there. To clarify this point, I will briefly recall the close relationships existing between France’s political culture and its policy of assimilation, Germany’s political culture and its long-standing tendency to keep immigrants in a precarious condition, and Britain’s political culture and its unequal form of pluralism. Afterwards, I will focus on the situation in Italy, which is now the fourth country of immigration in Europe. Finally I will point out the increasing influence of EU orientations on the migration policies of its member States.

Immigration and political cultures in France, Britain and Germany

France, as a strong centralized State that considers itself a great homogeneous nation, for a long time has regarded immigration as an issue calling for a policy of assimilation. This approach appeared to be quite natural in such a country, where immigration began as far back as the first half of the nineteenth century and played a major role in coping not only with recurrent shortages of workers, but also with a chronic demographic crisis, which appeared to be dangerous even for military reasons.

Immigrants, far from being allowed to use their ethnic and cultural identity as a strategic resource to reach a non-subordinate form of integration, were expected to shed it completely, in order to become “good Frenchmen”: a process that, according to its advocates, implied assimilation as for language, culture and, possibly, mentality and character too. In return, France extended to them the same rights enjoyed by the native French through “naturalization” (i.e., the granting of citizenship, called in this way not only in France because citizenship was perceived as the specific status of the “naturals” of a country: its native members). Moreover, even those immigrants who did not want to apply for French citizenship, or could not obtain it, gave birth to French citizens, because since 1889 citizenship has depended largely on jus soli.

Germany in contrast – in spite of being the European country with the largest number of immigrants (today about eight million) – used to deny its long-standing history as a country of immigration. Hence the phrase that since the ’50s German politicians have reiterated for more than forty years: “Germany is not a land of immigration” (Deutschland ist kein Einwanderungsland). Therefore, immigrants, even if targeted by massive recruiting campaigns, were long considered only “guest workers” (Gastarbeiter) — i.e., foreigners admitted temporarily and for working reasons alone. Their economic contribution might even be appreciated, but their settlement was not encouraged. They were allowed to live in the country even for lengthy periods, but without any significant change in their juridical status. Indeed, their acquisition of citizenship was not even envisaged and, therefore, their children born in Germany, if not in a position to become naturalized, were destined to remain foreigners, since jus sanguinis prevailed over jus soli. Far from favouring a “nationalization” of immigrants, Germans expected them to be ready to leave the country at any time, not only of their own free choice, but also as a consequence of an economic or political crisis or a government decision. Social policies did not aim at their assimilation, but rather at keeping them in a precarious condition, in order to favour their return to their own countries (which was even encouraged with incentives, but with limited results).

This policy, too, was deeply rooted in a particular political culture. Germany was the last of the great western European countries to be constituted into a nation State and this formed far later than the German nation. On the other hand, in the German culture, “belonging” to the nation — far from being conceived in subjective civic and political terms, as in France, where Renan (1882) could even define it as a sort of “daily plebiscite” — has always been conceived in objective, ethnocultural terms, as a fact linked to blood and land and to the putatively specificity of the German people.

Even after the Second World War, as a result of the sad division of the country, this notion of belonging continued to prevail over State membership. Thus, German refugees coming from Eastern Germany and even the descendants of the Germans who had settled many generations before in other eastern European countries have been regarded as potential citizens in their own right (and not as “foreign” immigrants).

On the other hand, this view of the nation has favoured a tendency to preserve the alleged homogeneity of the German people. The influence of this idea on immigration politics could not be clearer. In fact, for a long time, all norms encouraged the rotation of immigrants, to prevent them from putting down roots in the German land. Even the “temporary integration” envisaged in 1973 “to render the condition of immigrants more humane” was not implemented, since the economic crisis of the ’70s induced the country to close its borders to further foreign workers. But this entailed some unexpected consequences, such as the development of family reunification and the entry of more illegal and undocumented immigrants. Moreover, there was the arrival of masses of asylum seekers, unprecedented in peacetime, firstly from Third World countries and then from Eastern Europe. But this is a well-known story and it is not necessary to dwell upon it here.

The United Kingdom had a quite different social policy — as was its political culture, which, with well-known pragmatism, emphasized autonomy and decentralization and underlined the role of the local institutions and the intermediate social groups.

Both the British and the French immigration policies (as well as the German) had a strong ethnocentric bias, but these assumed quite different forms. In France ethnocentrism manifested itself in a universalistic way, with the claim that all immigrants, regardless of their race and culture, could become “good Frenchmen”. In Britain, on the contrary, it manifested itself in a particularistic way: there was no expectation that immigrants could ever become “good Englishmen” (or Scotsmen or Welshmen). Immigrants’ distinction was taken for granted and the main concern was to contain the damage that their presence might cause to the “British way of life”. However, in Britain the line between citizens and non-citizens was much less clear-cut than in France and Germany. This was due to a significant range of intermediate positions, depending on the prior existence of a special category, the citizens of the Commonwealth, who, if domiciled in Britain, even enjoyed the right to vote and stand for Parliament.

This does not mean that there were not great social problems. Suffice it to say that at the beginning of the ’90s a prominent British specialist, John Rex, could still define the condition of immigrants in terms of “segregated inequality”, in spite of the important measures that had been adopted since the ’70s to combat racial and ethnic discrimination. These problems became all too evident, owing to the recurrent ethnic riots in many towns that had been affected by the process of deindustrialization and in London itself.

The Italian case

Italy, with its 4,000,000 immigrants is now the fourth European country of immigration. Moreover, it is the first country of immigration in the Mediterranean basin, the most crucial area for the current and expected future migration towards Europe. It is also the first EU country for both the percentage of non-EU immigrants and the number of illegal immigrants, in spite of — or, rather, owing to — its tendency to regularize them periodically with great general amnesties (five extraordinary regularizations in fifteen years, probably a world record, and the last was even the largest ever carried out in Europe). In addition, there have been two other amnesties not officially declared.

The Italian attitude towards immigration is rather peculiar. This is due to various factors. First of all, Italy has become a receiving country after being for a century the European sending country with the largest number of emigrants (the turning point was reached in the ’70s). Besides, in Italy immigration did not begin in a period of reconstruction and economic development (as occurred in the north-western European countries), but rather in a period of deep economic crisis, characterized by a considerable increase in the unemployment rate.

Therefore, in Italy immigration has always depended much more on the push factors in the sending countries than on the pull factors in the receiving one. This trait — which is common to other southern European countries, such as Spain, Portugal and Greece — became even more apparent during the ’90s, owing to the dramatic events of that decade: the serious deterioration in the economic and social situation in many developing countries, the destructive wars in the former Italian colonies in the Horn of Africa, the implosion of the pseudo-socialist systems in eastern Europe, the crises in Albania and the breaking up of former Yugoslavia (two countries near the Italian borders). Briefly, in Italy immigration has been passively suffered rather than deliberately encouraged.

To all this we must add the effects of Italian political culture, a theme that has been object of very few studies. In effect, national identity itself in Italy has long remained a sort of taboo (due, among other things, to the Fascist exploitation of the national feelings). Italian scholars have preferred to investigate the so-called “political subcultures” (dwelling upon the distinction between the “red” subculture, of the areas under the prevailing influence of the communist and socialist parties, and the “white” one, of the areas under the prevailing influence of the Roman Catholic Church). More recently, they have focused their attention on the persistent contrasts between the northern, central and southern parts of the country or the eastern and western parts of northern Italy.

With regard to the Italian political culture, the first point to stress is its weak and ambiguous idea of nation. In effect, in Italy this idea has long fluctuated between the Romantic view (which emphasizes its ethnic and cultural “objective” elements) and the view inspired by the Enlightenment ideas (which emphasizes its civic “subjective” factors).

In Italy the Romantic concept, worked out by the first theorists of the Risorgimento, has fomented a considerable distrust in foreigners, which had already been fed by the persistent memories of the long sequence of foreign rulers that the country had suffered after the collapse of the Roman Empire. On the other hand, the Enlightenment view has nourished a cosmopolitan wishful thinking, which recently, under other influences, has assumed the form of a superficial and rhetorical form of multiculturalism.

Moreover, the national sentiment, according to the latest research, in Italy is far weaker than in the other European countries. Among the many reasons, it should be remembered that, since its origins, this sentiment in Italy has been tempered by the cosmopolitan heritage of both the Roman Empire and the Roman Catholic Church, as already appears in Dante’s works at the beginning of the XIV century. Later, owing to the effects of internal conflicts and foreign rule, it was contradicted by a strong attitude to mind one’s own affairs rather than the public interest. In fact, Italians, who lived for centuries under rapacious foreign oppressors, to defend themselves were obliged to develop private virtues and public vices.

More recently “civil religion”, to use Rousseau’s expression, or the “sense of State”, to use the old liberal definition, or rather “civicness”, as modern sociologists prefer to call it, has undergone the attacks of the two subcultures already mentioned: the one characterized by the ecumenical orientation of the Roman Catholic Church and the other epitomized by the internationalist stance of the leftist movements. Italy had the largest communist party in western Europe and many of its exponents are still active in political life, though under new labels, which enabled them to take part in the leftist governments of 1996-2001 and 2006-2008, and to lead one of them.

Moreover, Italy is affected by its historical legacy. The Italian national State was formed comparatively late (after all the others in western Europe except for Germany, if we consider the date of its proclamation, but even after it, if we take into account the important east-northern regions that could join Italy only after the First World War). Moreover, the formation of the national State was not due to the initiative of the core part of the country, as occurred in France, Britain and Germany and also in other Mediterranean countries, which offer important examples of what Anthony D. Smith termed the “ethnic origins of nations”. In Italy the first steps were taken by a small, peripheral and rather backward kingdom, the then still ethnically and linguistically composite Piedmont, whose ruling class could hardly speak Italian.

At a theoretical level we could discuss whether a weak concept of nation represents an advantage or a disadvantage for the social and cultural integration of immigrants, and our conclusion would also depend on our idea of “integration” (which I define as a condition of normal social relationships between individuals of different origin, class, culture and religion that allows civilised living in a relatively cohesive context). In fact, in Italy, the lack of a really organic policy for immigrants has given much scope to private initiatives (in particular, those of the social organisations controlled by the Roman Catholic Church, which have almost replaced public institutions in charity and other important activities).

On the other hand, the State, unable to enforce its own laws, between 1986 and 2002 approved five “special” amnesties, which covered eleven of the sixteen years of that period. This has caused a series of problems — both of a social nature and of public order — which has made it very difficult to face the situation in a rational and systematic way. Moreover, the last centre-left government (2006-2007) approved two concealed extraordinary regularizations.

This has led to two extreme positions. Some advocate the mass expulsion of illegal immigrants, with an essentially xenophobic stance. Others, in a rather irrational way, praise the continuous arrival of legal and illegal migrants as an opportunity to develop a marvellous multicultural society. In effect, these opposite stands, present to a certain extent all over Europe, in Italy seem to be even more radical than in any other country.

The communitarisation of the European migration policies

The situation presented above has considerably changed in the last years and probably will change further in the next future. The main factor has probably been the process of globalisation itself, which has affected both the migratory flows and the national political cultures. But also the incipient communitarisation of the European migration policies has played a role.

It is worth recalling that already in the ’50s the German Federal Republic, France, Italy, Belgium, the Netherlands and Luxemburg gave life to the first European communities, which later merged their officers (1965) and extended their borders owing to the entry of the United Kingdom, Ireland and Denmark (1973), Greece (1981), Spain and Portugal (1986), Sweden, Austria and Finland (1995). The main result was the constitution in Western Europe of a great “common market”, which, among other things, entailed the free circulation of the workers of the member States.

In 1985 five of the six initial States signed the Schengen agreement, which, between 1990 and 1996, was joined by all other member States, except the United Kingdom and Ireland. This agreement was not part of the community framework, but had a clear communitarian vocation, being open to all of its member States and only to them. Yet, when Denmark, Finland and Sweden joined, its main effects were extended to Norway and Iceland, which were associated with them in the Nordic Union.

The Schengen agreement, which came into force in 1995 for seven countries and some years later for the others, has progressively entailed the dismantling of the controls at the borders between the member countries and their reinforcement at the borders with other countries. It has also taken into account the aspects of immigration and asylum more closely connected with security and public order.

In the meantime the Convention of Dublin, which was signed between 1990 and 1991 by twelve member States, defined a series of issues concerning asylum, in order to harmonize the different national laws. Among the main results, there was the approval of some criteria to solve two hoary problems: “Asylum Shopping” (i.e. asylum claimed in more than one country) and “Asylum Seekers in Orbit” (i.e. asylum seekers shuttled from one country to another). This convention became effective in 1997.

The Treaty of Maastricht (which was signed on 7 February 1992 and came into force on 1 November 1993) marked a turning point in the process of European integration. It established the European Union, an international organisation with a clearer political orientation and wider competence than the previous communities. It also provided for an economic and monetary union, extended the functions of the European Parliament and attributed a new “European citizenship” to member States’ citizens. On the other hand, it affirmed the principles of “subsidiarity” and “proportionality”, which oblige the Union to avoid unnecessary interventions outside its exclusive competence.

The European Union is based on three “pillars”. The first, which comprehends the matters that were already competence of the old communities, uses the “supranational method”, which leaves only a secondary role to the States. The other two, which comprise the matters that were previously exclusive competencies of the States (namely international politics and common security: the second pillar and justice and home affairs: the third), use the “intergovernmental method”, which leaves the last word to the Council of Ministers. Migration, in spite of being recognized as an issue of “common interest”, was inserted into the third pillar.

However, five years later, the Treaty of Amsterdam (which was signed on 2 October 1997 and became effective on 1 May 1999) transferred almost all co-operation for justice and home affairs (including common action for immigration, asylum, visas and circulation of persons) to the first pillar. In order to facilitate this passage from the intergovernmental approach to the communitarian one, the treaty introduced a period of transition of five years from its coming into force, which however ended on 30 April 2004.

One of the protocols annexed to the Treaty of Amsterdam incorporated the Schengen acquis into the European Union, though by dividing it between the first and the third pillar. Only three countries failed to sign this protocol: Denmark, which preferred to remain free to choose whether or not to accept any new decisions, and the United Kingdom and Ireland, which had remained outside the Schengen Agreement itself (but later they decided to take part in some activities implemented in its framework, namely police and legal co-operation in criminal matters and the information system).

Though remaining defective at least under the geographical aspect, the communitarisation of the migratory policy has opened a new phase, characterized by a much more active role on the part of the European institutions. This has soon entailed the overcoming of the prevailing “defensive” character of the Schengen acquis.

The European Council of Cardiff (15-16 June 1998) requested the competent institutions of the Union to prepare an plan of action for implementing the “area of freedom, justice and security” envisaged by the Treaty of Amsterdam. This plan, which took into consideration immigration, asylum and temporary protection, was approved by the European Council of Vienna (11-12 December 1998).

In the following year the European Council of Tampere (15-16 October 1999) gave an important impetus to the homogenisation of the migratory policies of the EU countries. It recognized the need for a common policy for asylum and immigration and solicited an approximation of the legislations of the member States on the conditions for admission and stay of non-EU citizen. According to the Council, this development had to take into account both the economic and demographic conditions of the EU countries and the needs of the immigrants’ countries, without neglecting the historical and cultural links between some of them. In other words, it underlined the necessity of balancing the interests of the sending and the receiving countries. Therefore, to contrast illegal immigration, it advised the member States to favour legal immigration and use the partnership with the countries of origin and transit. It also stressed the opportunity of a progressive improvement in the immigrants’ status, in order to grant long-term legal residents rights and duties “comparable” to those of EU citizens. In addition, it decided to introduce common measures to fight racism, xenophobia and any kind of discrimination. As for asylum, after requesting the full respect of the obligations deriving from the Geneva Convention on Refugees (1951), it recognized the need to give protection to all persons in danger, even if ineligible as refugees according to that convention. It also emphasized the opportunity of defining a common procedure and a uniform status for asylum seekers.

After that Council the European Commission sent two important “communications” on asylum and immigration to the European Council and the European Parliament (22 November 2000). As for asylum, the commission underlined the importance of reconciling respect for humanitarian reasons and the need to oppose illegal immigration. On the other hand, it supported the proposal of a common procedure and a uniform status in all EU countries. As for immigration, after recognizing the right of any member State to limit the admission of non-EU citizens, it advanced the proposal to insert the residence permit and the work permit into one document, which had to become permanent after some years, and in addition asked for a common status for long-term residents. It also advocated a rapid homogenisation of the norms for family reunification.

According to the Commission, the integration of legal immigrants was a priority for the European Union: “a pluralistic society by its very nature, enriched by a variety of cultural and social traditions”, which were to increase in the future. Therefore, it was necessary to respect such traditions as well as the EU fundamental principles, described in terms of assertion of human rights and dignity, appreciation of pluralism and recognition that the existence of a society implies rights and duties for all of its members, be they nationals or not. However, owing to the length of time required for a real integration, special attention had to be paid to immigrants’ children, including those born in the EU, to prevent their social exclusion and the consequent risk of their drift to crime. To fight illegal immigration, according to the Commission, it was essential to facilitate both legal immigration and rejection, or rapid expulsion, of illegal migrants and bogus asylum seekers. With this objective, all EU member countries were invited to set up talks and to implement partnerships with the countries of origin and transit.

This was a “comprehensive strategy”. Immigration was regarded as a broad long-term process, which required different kinds of measures, including co-operation for the economic and social development of the sending countries. Only this development, in effect, could control the push factors, which in this phase seem to be almost everywhere far more important than the pull factors.

The European Council of Laeken (14-15 December 2001) confirmed this trend towards a common policy of asylum and immigration, in spite of the resistance of some national administrations. Yet, some difficulties emerged in the European Council of Seville (22 June 2002): the main question was how to treat the developing countries unwilling to oppose illegal migration. The final compromise decided to reward the more co-operative countries without damaging the others. However, it was decided that all future agreements of co-operation with developing countries should include norms obliging them to control the flows and to re-admit their illegal migrants.

In this period, however, Europe had to face a new problem: the threat of Islamic fundamentalism, which had become evident after the tragic attacks on the Twin Towers in New York and the Pentagon in Washington D.C. (11 September 2001) and the subsequent US interventions in Afghanistan (since 7 October 2001) and Iraq (since 20 March 2003) with the support of three EU countries (the United Kingdom, Italy and Spain) and a then candidate country (Poland). The seriousness of this threat was proved by the terrorist outrages committed in Madrid (11 March 2004) and London (7 July 2005) and the attempts against British, Italian and Polish objectives in various parts of the world. This global crisis obliged the European institutions to re-examine the policy of immigration in the light of common security. Therefore, in recent years a great deal of attention has been paid to border control. This clearly emerged during the semester of the Italian presidency (July-December 2003), when, inter alia, the member States agreed on the establishment of a European Agency for the management of operational co-operation at the external borders, which, however, was established only on May 1, 2005 (with the name Frontex, from the French “Frontières extérieures”) and became effective in the following October.

In the meantime the EU became larger, owing to the entry of eight Eastern European countries (Poland, Hungary, the Czech Republic, Slovakia, Slovenia, Estonia, Latvia, Lithuania) and two Mediterranean countries (Malta and Cyprus) on May 1, 2004 and two more Eastern European countries (Bulgaria and Romania) on January 1, 2007. On October 29, 2004 the old and new EU member countries signed a Constitutional Treaty paying much attention to immigration and related phenomena. This treaty proclaimed the pluralistic character of Europe, “united in its diversity”, and affirmed that the Union was founded on “the values of human dignity, liberty, democracy, equality, the rule of law and human rights”. It also emphasized “pluralism, tolerance, justice, solidarity and non-discrimination” together with the respect of “cultural, religious and linguistic diversity”. Moreover, it committed the Union to prevent and combat “crime, racism and xenophobia” and declared the willingness to implement “a common policy for asylum, immigration and the control of the external frontiers, based on solidarity between member States and fair towards non-EU citizens”. The treaty did not enter into force since it was rejected in two countries (France and the Netherlands) where it had been submitted to referendum. Yet, all preparatory and subsequent works have exerted an important influence on the orientation of the member States.

According to that treaty, the Union had to develop a common immigration policy in order to ensure an efficient management of migration flows (art. III-267). To re-launch the debate on this theme, in January 2005 the European Commission issued a Green Paper on a possible EU approach to manage economic migration. This document was conceived as a basis for a policy plan on legal migration, with admission procedures capable of responding promptly to fluctuating demand for migrant labour. The basic idea was that, owing to their demographic ageing, EU countries required more sustained immigration flows to meet the needs of their labour market. Therefore, EU had to attract economic migrants by assuring them a secure legal status and to favour their integration by granting them a clear set of rights. The Commission recognised that the number of economic migrants to admit had to remain competence of the member States, but underlined that the admission of third country nationals in one member State could affect the others in many ways (due to their indirect impact on the EU labour market and to their right to travel within the Schengen area, to deliver services in other member States and even to move there after acquiring a long-term resident status). Therefore, according to the Commission, it was necessary to agree transparent and harmonised common rules for admitting such migrants.

Some months later (10 May 2005) the Commission launched a 5 year Action Plan for Freedom, Justice and Security that detailed proposals for EU action on terrorism, migration management, visa policies, asylum, security, the fight against organised crime and criminal justice. This plan (to be known as the Hague Programme) was presented as a cornerstone of the Commission’s Strategic Objectives for 2010, built upon the basic ideas of prosperity, solidarity and security.

The plan singled out ten priorities for the next five years. As for migration and related issues, it defined a balanced approach envisaging a common immigration policy at the Union level and a stronger fight against illegal migration and trafficking in human beings (notably women and children). Moreover, it further developed an integrated management of external borders and a common visa policy and implemented the work to establish a common asylum area.
To fulfil the mandate included in that Programme, before the end of the year (21 December 2005) the Commission adopted a Policy Plan, primarily focused on economic immigration. This document did not contain any legislative or operational proposal, but defined a road-map for the remaining period of the Hague Programme. It listed the legislative initiatives and the other actions that the Commission intended to take in order to pursue the development of the EU legal migration policy.
The results of these measures (and others, on which I cannot dwell here) have been object of the subsequent Reports on Migration and Integration, annually published by the EU Commission and recently arrived at their 4th year.

The convergence of migration policies in EU countries

The process summarized above clearly explains the convergence of the migratory policies of EU countries. I’ll mention only some exemplary changes occurred in the three countries discussed above, France, Germany and the United Kingdom, with a final reference to Italy.
France has come to recognize the ethnic communities as proper partners of its migration policies and no longer declares that accepting their specific traits would be a form of ghettoïsation à l’americaine. To meet with the particular difficulties of immigrants, special measures have been approved, especially as for housing. Also an intercultural approach has been partially introduced, both in education and in everyday life. Some well-known scholars have even suggested a “French form of multiculturalism”: a sort of compromise between the traditional “republican” values of the country and the religious and cultural claims of the immigrant groups.

An important step in this direction was the new law on secularism (laïcité), approved in 2004. It introduced an explicit prohibition of entering State schools with “conspicuous” religious symbols (such as large Christian crosses, Islamic veils, Jewish kippahs and Sikh turbans), but it also allowed minor signs of faith and origins. Moreover, its advocates, though confirming the prior orientation for the religious and political neutrality of the public institutions, asked them to respect all religious and cultural sensibilities whenever possible, with explicit reference to schools, barracks, cemeteries and hospitals.

In fact, “owing to the change in the spiritual situation that had taken place in the last century”, that law interpreted secularism as an important means of favouring the cohabitation of people of various origins, cultures and religions. Secularism was re-defined as a measure to favour not only mutual tolerance, but also the integration of immigrants. This approach (quite different from the old “republican” formula, worked out when it was essential to contrast the then reactionary claims of the Roman Catholic Church) was to foster the development of a new culture, which could improve the condition of Muslim women and to promote sexual equality without pretending an immediate assimilation of uses and customs that even in Europe had emerged enough recently.

The United Kingdom considers immigration an important resource, in spite of the well-known economic and social difficulties that have caused strong resistance among the natives and violent reactions among the immigrants. Even the long-term consequences of immigration are substantially accepted, though some scholars and politicians underline the need to “reclaim Britishness”, to quote the title of a book published by an influential think tank of New Labour. On the other hand Prince Charles – who, if and when he ascends the throne, will inherit the function of defensor fidei – has promised to act in favour not only of the Church of England (of which he would become the head), but of all religions present in the country.

As for migration policy, while legal immigration for working reasons has been facilitated, illegal immigration (including that adducing political reasons) has been more strictly controlled. The law on asylum, immigration and citizenship, approved in 2002, has limited the flow of asylum seekers, who had become quite numerous (more than 100.000 in that year). Among other things, this law provides for the biometric identification of the immigrants: a meaningful measure in a country that since the Second World War has lived without identity cards. Yet, this absence, which made the stay of illegal immigrants much easier, has finished, owing to this “time of global uncertainty with an increased threat from international terrorism and organized crime” (to quote Queen Elisabeth herself) and “illegal immigration” (according to the words added by the then Prime Minister Tony Blair). The law makes both naturalizations and long-term stay more difficult and requires all foreigners who intend to settle in Britain to learn English (or Gaelic or Welsh, according to the place). But it also introduces important measures aiming at their integration.

Germany, which in the year 2000 abandoned its traditional denial of being a country of immigration, has also dismissed the idea of a merely temporary integration of immigrants. Suffice it to say that now immigrants meet much less difficulties to become naturalized and their children born in Germany quite easily acquire German citizenship when they reach 18 years of age. Also the request to immigrants to learn German seems to be due to the new acceptance of their permanent settlement rather than to a persistent resistance to them.

The first immigration law, which became effective on 1 January 2005, aims at coping with several problems, among which the granting of refugee status for reasons not considered before, such as persecution by non-governmental groups, discrimination for sexual orientation and fear of genital mutilation. It also contains new provisions related to internal security, such as the easier expulsion of aliens suspected of terrorist activities or involved in preaching hatred and some restrictions of movement for other extremists. But it provides important opportunities for immigrants willing to integrate.

As we can see, beyond the persistent differences between the three countries, there is a significant convergence in their policies towards a social integration of immigrants with respect for their cultural identity: the new “common policy” proposed by the European Commission in the year 2000.

Paradoxically, the first country to move in this direction, even anticipating EU communications and directions, was Italy, which became a country of immigration only in the ’70s. In fact, the idea of the social integration of immigrants with respect for their cultural identity already inspired its first immigration law, passed in 1986 by a leftist government, and this approach was confirmed by the three subsequent laws: those approved in 1990 and 1998 by other centre-left governments and that approved in 2002 by a centre-right government (which is still in force, in spite of the harsh criticisms of the leftist majority that ruled the country between May 2006 and May 2008).

This paradox may be easily explained. In Italy immigration began in the second phase of post-war migration, which was deeply characterized by the influence of so-called “new international division of labour”, and has become important in its third phase, which developed under the influences of globalisation and Europeanisation. Besides, as we have already mentioned, under many aspects Italian political culture is a sort of compromise between the French and the German types. We may add other important factors. In Italy the influence of the “universalistic” approach of the Roman Catholic Church has always been very strong and also the influence of the “proletarian internationalism”, officially professed by the leftist movements, was quite remarkable. Furthermore, strong and widespread opinion in favour of the process of European integration has made Italy very sensitive to the positions of European institutions, even before their formal declaration, while the growing crisis of the policies of the countries that had already experienced large-scale immigration suggested the need to try a new way.


Globalisation, as I have already stressed, has deeply affected the patterns of immigration almost everywhere, making them much more similar than before. This has facilitated to a large extent both the work of the EU institutions and the acceptance of their directives and suggestions by the member States.

However, we are only at the beginning of a long road and many contradictions still emerge even in the new approach to immigration. It will be the duty of the EU member countries to move ahead, also overcoming the new difficulties arising from the enlargement of the Union, and, particularly, the increased difference between them in history, traditions, conditions and, of course, political culture.

September 2008


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Umberto Melotti is a Professor of political sociology in the Faculty of Sociolgy at the Università di Roma “La Sapienza”.