European Immigration
A Sourcebook
ASHGATE
Chapter 27
Concluding Remarks1
Ruby Gropas and Anna Triandafyllidou
According to the latest data presented by the EU Commission (European Commission, 2006, p. 3),
on 1 January 2003, 15.2 million persons residing in the 25 Member States were third-country
nationals. This amounts to 3.35 per.cent of the total EU-25 population. Moreover, the two million
population increase that was registered in the EU-25 in 2005 was mainly due to registered net
immigration of 1.7 million. Positive net migration has been recorded in almost all Member States
with the exception of Estonia, Latvia, Lithuania, the Netherlands and Poland, while Cyprus, Spain
and Ireland registered the highest rates.
Although such generalized information is useful in providing us with the global picture of
migration trends, what the preceding chapters of this book have highlighted is that it is nearly
impossible to provide accurate information on the size and nature of the third-country nationals'
population in the EU. Available statistics do not offer a consistent and reliable numerical picture of
immigrants within the EU. Each Member State uses different sets ofstatistical categories, different
definitions, different ways of recording residents and citizens. Stocks and flows of immigrant
populations (presented in the preceding chapters) are rarely, if at all, directly comparable.
Despite these difficulties in developing a meaningful comparison between the countries studied
in this volume, we have to note that a basic trend is common across the EU: the past few decades
have been characterized by significant population movements across and within the European
continent. Europeans have increasingly migrated from east to west and people from around the
world have increasingly migrated to EU Member States. All Member States, regardless of their
geographical and population size, and irrespective ofprevious migration history, have experienced
population movements that have altered the EU demographically, socially and - all the more
so - politically. Migration is the main determinant of demographic growth in the EU and will
unquestionably have far-reaching consequences and implications for the socio-cultural landscape
ofEurope, as well as for its labour markets and economies.
The 25 country chapters ofthis book provide a briefpresentation ofthe immigration situation in
each ofthe European Union Member States, the size oftheir immigrant population and recent trends
of inflows and outflows. Each chapter has commented upon the different definitions of migration
categories in the national policies as well as the different types of migration statistics kept by each
country. Each chapter has also offered a brief overview of migration policy developments during
the last 15 years or so and has outlined the main provisions and conditions for the participation
of immigrants in public life. Last but not least, each chapter has discussed the main media and
political debates in relation to migration.
Against this background, this chapter highlights and discusses critically some aspects of the
national studies with special reference to a typology of countries (in relation to their migration
experience), a typology of migration pathways, and a typology of migration regimes. These
typologies constitute a first attempt to provide an overview and to compare different EU countries
This chapter draws from Cyrus et al. (2006).
362 European Immigration
without over-generalizing and with a view to recognizing and taking into account their different
migration experiences. In other words, our aim in this chapter is to draw some comparative readings
of the trends and issues currently characterizing EU migration patterns, while also pointing out
some of the most marked differences.
Comparing experiences of migration
In this section, we propose a provisional typology (see Table 27.1) of migration experiences
among EU countries which takes into account the following factors: relations between sending
and receiving countries (for example, colonialism), past migration experience (earlier or recent
conversion from senders to hosts, experience in migration management and integration policies),
the size of the immigrant population (in absolute and relative terms, that is as percentage of the
overall population), and the factors that have triggered migration flows (geopolitical changes,
political or economic factors).2
,Qldhostcountries
During the first decades ofreconstruction following the end ofthe Second World War, northern and
western EU Member States shifted from being senders (for instance to the USA,Australia or Canada)
to becoming hosts. France, Germany, Belgium, the Netherlands and the UK in particular have a
relatively long immigration history related to their colonial past but also due to labour shortages
after the end of the Second World War. These countries ran state or company-led recruitment
schemes from Southern Europe as well as northern Africa, Asia and the British Commonwealth.
Austria and Denmark joined this group more recently (since the 1970s) even though they have
no special colonial ties to any countries. The migration pattern they have experienced is similar:
economically motivated migration with migrants and their families gradually settling in large
numbers.
At present, these countries are generally faced with ageing first-generation immigrants and the
challenge ofcmnbating the social exclusion and marginalization of second- or third-generation
immigrants. In parallel, the economic difficulties, or even crises, that characterize most of these
economies and the accompanying social frustration are manipulated by extreme right-wing parties
to gain voters. This has been steadily leading to the exacerbation of xenophobic reactions on the
part ofthe majority populations. Religion, in particular Islam, is also becoming increasingly visible
as a dividing factor between 'native'3
populations and those of immigrant origin. These countries
certainly have a long experience in migration and admission policies and have arguably developed
elaborate (more or less successful) integration policies.
2 This typology pays less attention to the new forms of migration (King, 2002) (for example, shuttle
migration, gendered migration, youth and study migrations, eo-ethnic movements, asylum seekers under
humanitarian protection) and to special aspects ofa country's legislation related to eo-ethnic retumees for
instance. These aspects are discussed in the section on migration pathways.
3 The term 'native' is used in inverted commas to note that populations of immigrant origin are also
often natives ofthe country of settlement.
Concluding Remarks 363
Table 27.1 Typology of countries in relation to their migration experience
Category Type of migration pattern EU Country
Long migration history
Sizeable migrant population
Initially economic migration
reunification
later followed by family Austria, Belgium,
Old hosts
Recent hosts
Countries in
transition
Small islands
Non-immigration
countries
Currently: only high skill migrants welcome, limited low
skill programmes for specific sectors
Advanced integration policies and relatively liberal
citizenship policies
Public debates on migration are politicized and mainly
concern the dilemma between multiculturalism and
assimilation
Countries on the geographical periphery ofEurope
Transition from emigration to immigration in the late 1980s
or early 1990s
Large immigrant populations developed quickly
Ad hoc immigration policy planning (marked by repeated
regularization programmes in the Southern European
countries)
Limited and still hesitant integration policies
Public debates on migration focus on control, criminality,
fears of losing national cultural authenticity
Former communist countries in Central Europe
Caught in between sending, receiving and being a place of
transit for migrants
Performing well in terms of their economic and political
transition to capitalism and democracy
Small legal immigrant populations but potentially growing
undocumented immigration from Eastern European states
outside the EU
Non-existent integration policies, debates on immigration
are very limited
Very small island countries facing increasing migration and
asylum-seeking pressures
Ad hoc immigration policy planning and very limited
integration policies
Still experiencing emigration oftheir own citizens
Public debates on immigration concentrate on fears of being
'inundated' by foreigners
Very low levels of new immigration whether legal or
irregular
Important population changes and minority formation in
the course of the 1990s, resulting from recent nation state
building and ethnic unmixing (Brubakers 1996)
Denmark, France,
Germany,
the Netherlands,
Luxembourg,
Sweden, United
Kingdom
Greece, Italy,
Portugal,
Spain, Ireland
and Finland
Czech Republic,
Hungary and
Poland
Cyprus and Malta
Estonia, Latvia,
Lithuania,
Slovenia and
Slovakia
364 European Immigration
During the 1990s, a gradual shifttook place towards increasingly restrictive admission policies,4
and towards a revisiting of their own integration policies. In an environment of heightened
security concerns, the value and success of multicultural citizenship policies adopted by most
of these European countries has increasingly been questioned (Gropas, 2007). Recent trends in
their integration policies are marked by new (and in many cases stricter) integration obligations
towards new immigrants, for instance through obligatory language and civic orientation courses.
A telling example is the case of the Netherlands where, as of2005, immigrants coming for family
creation must pass an integration test in the Dutch embassy in their country of origin. Also, the
Dutch Government has recently announced plans to require tests of Dutch language proficiency
and knowledge of Dutch culture for labour migrants applying for an entry visa.
Recent host countries
Over the course ofthe last two decades, countries on the geographic periphery ofthe EU have seen
their traditional emigration patterns being reversed and have become destination countries. This is
the case for Southern European states (Greece, Italy, Portugal and Spain) and for smaller countries
in the western and northern periphery ofthe European Union (Ireland and Finland).
In part, this reflects a gradual improvement in the economic situation and the living conditions
in these countries. It has also, however, been an unintended side effect ofthe restrictive immigration
measures taken by the UK, France, Germany and Switzerland since the mid-1970s. Moreover,
immigration patterns in these countries have been significantly affected by the implosion of the
communist regimes in Central and Eastern Europe and the liberalization ofpopulation movements
from east to west.
The immigration experience in this group has been characterized by the absence of consistent
migration policies - that is, policies with a long-term approach to the issues of admission and
integration. This has led to a high number of migrants remaining in these countries unofficially
or without proper documentation and to high numbers of illegal immigrants. This is particularly
the case in Southern European countries, which have land and sea borders that are difficult to
patrol and control. The irregular or illegal status that is common to large segments of the migrant
population has implications not only for their employment conditions but also for their effective
integration in the host society.
The large inflow ofundocumented immigrants that has been common to the southern Member
States has led to repeated regularization programmes as governments gradually admitted that the
immigration situation was getting out of their control and that large populations were present in
the country illegally. Since 1986, there have been five such programmes in Italy involving more
than two million immigrants, and Greece has implemented three similar programmes ofwhich the
most recent was in 2005. Since 1992, Portugal has adopted four regularization initiatives and Spain
began its third and most far-reaching regularization scheme in 2005.
Finland and Ireland have also recently been transformed from countries of emigration to host
destinations and the largest influx came with the end of the Cold War. Traditionally, Finland has
been a country with very restrictive migration policies, mainly due to its geographical position
(bordering with the Soviet Union during the Cold War), while Ireland's economic situation did not
render it a destination choice for migrants. Political and economic changes in the 1990s altered
this, leading to a significant change in the socio-demographic and economic landscape of both
countries. Unlike the southern EU countries in this general category, Ireland and Finland have not
4 Immigration policies in these countries had put a halt to recruitment offoreign labour since the mid-
1970s as a result ofthe oil crisis and the slowing down oftheir economies.
Concluding Remarks 365
been faced with noteworthy illegal immigration and they have been more proactive in formulating
integration policies for the influx of newcomers and in particular for the integration of asylum
seekers and refugees.
Countries in transition
The third group of countries experienced major changes in migration patterns since the 1990s
fundamentally as a consequence of the 1989 'Autumn ofNations.' While these new EU Member
States experienced large emigration towards the other EU states in the early to mid-1990s, they
have also become transit migration countries and appear to be in the preliminary stages ofbecoming
hosts ofthird-country immigrants. The inflow ofimmigrants is primarily from former Soviet Union
countries (and in particular from Ukraine) or other neighbouring nations with which there was a
formal relationship (for example between former Czechoslovakia and Yugoslavia).
In addition, small, albeit well organized, immigrant populations in these countries come
mainly from Asia and in many cases are the continuation of migratory movements during the
Communist times. Thus, we find small groups of Vietnamese or Chinese emerging in Poland or
the Czech Republic. In addition, Central and Eastern European Member States have also become
an attractive destination for entrepreneurs from Western Europe and the USA. These immigrants
are predominantly involved in economic activities in the tertiary sector as highly-skilled managers,
experts, consultants or scientists.
In all cases, the new Member States have encountered a series of challenges in the field of
integration and administrative hurdles (lack of qualified personnel and financial means) in
implementing integration initiatives and the national action plans for employment (European
Commission, 2006, p. 7).
Small island countries
The islands of Malta and Cyprus have experienced increased immigration, both as transit and
host countries, since the 1990s. Cyprus has received both legal and irregular migration in a
pattern similar to that of Greece or other Southern European countries. Malta, by contrast, has
been concerned with increasing amounts of illegal migration and growing numbers of asylum
seekers and refugees who reach its coasts on wrecked dinghies from North Africa. What these
two countries share is their small size, which makes even a few thousands or tens of thousands of
foreigners a large population; their lack of previous experience with migration management and
integration policies; and the developing xenophobic and racist attitudes among their populations.
Debates in these countries frame migration in terms of fear and threat. At the same time, both
island countries continue to experience emigration oftheir youth, who go to study abroad in other
European countries and often remain there.
Non-immigration countries
For some of the former communist states, migration is still of minor importance. This is the case
for the Baltic States, and also for Slovenia and Slovakia. With regard to the Baltic States, the
previously steady migration flows from the former Soviet Union have generally ceased since the
1990s. Moreover, all three countries experienced a population decrease in the early to mid-1990s
mainly due to the repatriation of Russian-speaking residents to Russia or other former Soviet
states. These outflows have eventually levelled out after the first few years. The Russian speakers
who chose to remain in these three countries have been turned into ethnic minorities through the
366 European Immigration
process of nation building. In the case of Lithuania, minorities were given citizenship status and
are therefore recognized as ethnic minorities. In the case of Latvia and Estonia, many among the
Russian speakers were unable to acquire citizenship status and have therefore been labelled as
immigrants who are permanent residents in those countries. Theoretically, these populations may
be considered immigrants but they are in most cases second generation (as it was their parents who
moved within the Soviet Union) and have known no other country as their own. The linguistic
issue, and in particular the question of education in minority languages, has been the main policy
issue in recent years and the main topic of public debates on 'immigration'.
The situation of Slovenia resembles that of the Baltic States to a certain extent, as part of its
population stems from internal migration from other states of former Yugoslavia. There again,
nation state building has led to problematic citizenship policies which were further complicated by
the war in neighbouring Croatia and Bosnia. Slovenian immigration has mainly to do with former
Yugoslav citizens from Bosnia or Serbia who now reside in Slovenia with or without appropriate
legal status.
Slovakia has also been grouped within this set of countries because it has also experienced
virtually no immigration other than transit migration towards the west and because it has similarly
been affected by nation building. Slovakia has accepted a number of Czech citizens but has also
'lost' part of its population which chose to stay in the Czech Republic and naturalize. Currently,
debates about migration have mainly to do with the movement of Roma populations between
Slovakia and the Czech Republic and are tainted by prejudice and racism against this ethnic
minority, regardless oftheir citizenship.
All five countries in this group may be characterized as non-immigration countries, as they
have experienced very little immigration or emigration in recent years, except for population
movements related to nation building. The special nature of these cases is that populations did
not actually move; it was the borders that moved over them after the end of the Cold War, thereby
changing their status or requiring them to change their citizenship.
Immigration pathways
The existing diversity in immigrant populations within the 25 EU Member States is the result of
the history of migration flows in Europe, specific political and economic configurations between
sending and receiving countries, geopolitical circumstances, and national differences in immigration
policies. Below, we provide for a typology of the main 'old' and 'new' forms of migration in
Europe today. Our classification includes the old typical labour migrations that were triggered
by economic inequalities between the sending and the receiving countries and were managed
through recruitment schemes and bilateral agreements. It also attempts to encompass new forms
of migration that are more fluid, often irregular, involve circular or pendular movements between
several countries, and are related to specific economic sectors of seasonal or heavy jobs.
To provide a structured scheme for comparison and categorization, we use here the term
'migration pathways' borrowed from the work of Psimmenos and Kassimati (2003). The term
'pathways' suggests sets of relationships, policies and opportunities that come together to form a
specific pathway, a channel through which information and people flow between the sending and
receiving country.
Based on this understanding and following from a comparative reading of the 25 country
overviews, we have. identified eight. such main migration pathways that are analysed in turn
below:. tile pathway of co-ethnics and returnees, the colonial and post-colonial pathway, the pre-
1989. internal migration pathway, ·the labour migration pathway, the asylum-seeking pathway,
Concluding Remarks 367
the,pathway of temporary and seasonal"migration, the 'gold-collar' pathway and the pathway of
irregular migration.
The pathway ofco-ethnics and returnees
Favourable admission patterns for co-ethnics, returnees and their descendants are widespread across
many Member States. In each case, preferential reception schemes are justified on the basis of
unique historical circumstances and are excluded from general, restrictive immigration policies.
Two types of migrants can be distinguished within this pathway of migration: returnees and
co-ethnics. Returnees are individuals born in the EU country, who have emigrated and have
subsequently returned after a long absence abroad. Co-ethnics are descendants of emigrants or
members ofeo-ethnic communities abroad who result from past migration movements. Co-ethnics
may also be populations which are ethnically and culturally akin to the receiving country but which
have never, in this or previous generations, lived in that country. In practice, the two categories are
often merged, while the logic that regulates policies towards them is the same: they are ofthe same
ethnic origin as the citizens ofthe receiving country.
While some EU Member States have a larger presence ofreturnees, other Member States have
a higher proportion ofco-ethnics. Poland is one country that clarifies this distinction; persons who
emigrated from Poland as adults and returned to the country after the system transition (mainly
from the USA) are considered returnees (also referred to as expatriates) whereas co-ethnics are
the descendants of settlers and deportees, mainly from Kazakhstan. In the case of Germany,
immigrating co-ethnics (Aussiedler) come mainly from Kazakhstan, whereas in Finland coethnics
come from Estonia. Greece has received co-ethnics (Pontic Greeks) from the former Soviet
Republics ofGeorgia, Kazakhstan, Russia and Armenia, and a large number ofethnic Greeks from
Albania. Portugal's retornados are the descendants offormer Portuguese settlers and come mainly
from Angola and Mozambique. Swedish Finns and mainly Ingrian Finns are currently regarded as
return migrants with special status in Finland. Hungary is also a country with a high number of
immigrants of Hungarian ethnic origin. Indeed, since 1989, immigrants and temporary workers
are mostly from ethnic Hungarian communities beyond the borders ofcontemporary Hungary (for
example Romania, Ukraine and former Yugoslavia). Another country that has experienced eoethnic
migration, albeit in small numbers, is Italy. Here, immigrants (mostly from Argentina) who
can identify Italian parenthood up to three generations prior, are still considered co-ethnics and
have a preferential channel to naturalization. Finally, there has been an inflow of returnees towards
the Baltic countries in recent years. This migration predominantly consists ofa high percentage of
repatriated citizens (returnees) who returned to Latvia, Lithuania and Estonia when independence
was restored.
In all cases, the reception of co-ethnics and returnees is better than that of 'other' immigrants.
They usually enjoy the right to naturalize through preferential channels and, even if they do not
have the right to naturalization upon arrival, they enjoy privileged conditions compared to other
migrants as regards the financial and institutional support provided to them by the state with a view
to helping them settle down and integrate into society as smoothly as possible.
The colonial andpost-colonialpathway
This pattern mainly pertains to Member States with a colonial past, and seems to have worked
as a de facto substitute for the recruitment of workers. This is particularly the case for the UK,
France, the Netherlands and, to a certain extent, Belgium, Spain and Portugal. In these countries,
immigrants were granted access to the territory as citizens of the former colonies, with certain
368 European Immigration
sets of rights associated with their status. The United Kingdom has received several immigrant
groups from Commonwealth states of the West Indies, Asia and Africa, while France has received
immigrants mainly from former African colonies (for example West Africa and the Maghreb). The
Netherlands has welcomed former colonial subjects from Indonesia and Suriname, and Belgium
has received migrants from its former African colonies such as the Congo (former Zaire), Rwanda
and Burundi. Spain has large immigrant communities from Ecuador, Argentina and Peru, and the
main countries of origin of immigrants in Portugal are Portuguese-speaking African countries (for
example Angola, Cape Verde, Guinea Bissau, Mozambique), and Brazil. Initially, immigration
from Africa and Asia mainly took place within the framework of post-colonial migration, but the
receiving countries gradually put legal obstacles in place so as to curb post-colonial immigration.
In terms of immigrant integration, the colonial relationship has offered some advantages to the
migrants in that they were usually familiar with the language, the culture, and even the institutions
and political system ofthe colonial 'mother' country. It also brought with it important disadvantages
such as prejudice, discrimination and racism that were built into the social and political system of
the country ofsettlement and that were widespread among its population. Moreover, some colonial
populations had had particularly traumatic and divisive experiences in their relationship with the
mother country (for example Algerians in France) that could not be easily forgotten or settled
(emotionally and politically) even ifthey lived in the mother country for decades.
Pre-I989 internal migration pathway
This pathway has mainly affected countries located in Central and Eastern Europe and the Baltic
region. During Soviet rule, large population movements took place and, as a consequence, large
numbers of Soviet citizens (mainly but not always of Russian nationality) settled in areas that
became independent states after 1989. In these countries, internal migration movements were
typical ofthe Communist era.
Communist countries in Europe had no migration relations with countries outside the Warsaw
Pact. The governing regime tightly controlled emigration, and political reasons for emigration
were often intertwined with economic motives. The Czech Republic (then part of Czechoslovakia)
experienced immigration within the framework of 'international aid cooperation' schemes and
the consequent intergovernmental agreements drafted between Czechoslovakia and other socialist
countries including Poland, Yugoslavia, Hungary, Cuba, Mongolia, Angola and North Korea.
In contrast, it is worth noting that there was hardly any immigration to Hungary between 1949
and 1989, with the exception of two politically motivated movements when Greek and Chilean
communists were granted asylum protection in the early 1950s and 1970s.
Throughout the large-scale industrialization of the 1960s and 1970s, significant numbers
of people from different parts of the Soviet Union (mostly from Ukraine, the then Byelorussia
and Russia) settled in the three Baltic States. Because of nation state (re-)building, most of the
settlers are now identified as foreign nationals. However, these populations are not the outcome of
international migration but, rather, of formerly internal migration and the reshuffling of states and
their borders.
What is common among these movements is that they all happened within the context of a
centrally governed economy and an authoritarian society. They all resembled internal movements
within some sort of'empire' which was the communist part ofthe world. In some cases, populations
that used this pathway to migrate were offered the opportunity to naturalize and to become fully
integrated into their societies of settlement while, in other cases, naturalization has been very
difficult and these groups remain labelled as foreign immigrants despite their long-term settlement
in the receiving countries.
Concluding Remarks 369
The labour migration pathway
This pathway includes two main patterns of movement that have historically been inter-related:
initial labour migration that came as a response to labour recruitment by the receiving countries and,
later, family reunification or family formation migration. This latter had to do with the settlement
of the workers in their host country and their wish to bring their family over or to form a family
with a person from the same country of origin.
The labour migration pathway is probablythe numerically most important one in Europe today.
It has been the dominant form of migration in Western and Southern Europe from the 1950s up
to the present day. Recruitment programmes were implemented in the older host countries of
Northern and Western Europe from the late 1950s until the early 1970s. These programmes, also
known as guest-worker recruitment programmes, were established through bilateral governmental
agreements mainly with Southern European and Mediterranean countries (such as Morocco and
Turkey).5
The recruitment was initially intended to be strictly temporary and recruited workers were
expected to return to their country of origin. However, the return aspect ofthe agreements was not
implemented in a strict and consistent manner. Instead, policies allowing for the repeated renewal
of residence rights were commonplace. In the end, this led to settlement and subsequent family
reunification migration. This has been the case for immigrants from Italy, Greece, Spain, Portugal,
Yugoslavia, Turkey, Morocco and Tunisia who have settled predominantly in Germany, Sweden,
France, Belgium, the Netherlands, Austria and Luxembourg. Although Italy, Greece, Spain and
Portugal are EU Member States today and immigrants in these countries enjoy free mobility within
the Union, immigration from the former Yugoslav states, Turkey and North Africa is still of thirdcountry
status. Today, family formation (marrying a partner from the parents' country of origin) is
an important source of new immigration linked to this historical recruitment pattern.
The asylum seekingpathway
Since the mid-1970s, Western European countries have received three major migration flows from
other parts of Europe that were initiated by political persecution and war. -The first wave was
from the socialist countries of Central and·Eastern Europe. These migrants were perceived as
legitimate refugees escaping communist suppression and received preferential reception until the
end of the 1980s. Due to restrictive passport regulations in most socialist countries, the largest
refugee migration came from the least restrictive Polish People's Republic. These migrants went
primarily to Germany and secondarily to Italy, France and Greece when martial law was imposed
in Poland in 1981.
The second most important refugee migration wave came from Turkey in the 1980s when
members ofthe Kurdish,minority and the religious minority ofAlevits sought refuge predominantly
in Germany, but also in Greece.
The third wave ofasylum-seeking migration was a result ofthe civil warin.former¥ugoslavia.
Between 1991 and 1995, hundreds of thousands of refugees arrived in Germany, the UK, France,
Austria, Italy, Ireland, Sweden and Slovenia. These refugees only received temporary protection as
civil war refugees and the majority have returned to their home country. However, a considerable
proportion has remained in the receiving countries, among them Roma people who in particular
have experienced problems of discrimination and intolerance in the countries of settlement.
5 There were also some bilateral schemes with more geographically distant countries, such as the
scheme linking Germany and South Korea.
370 European Immigration
From the mid-1970s until the early 1990s, the number of non-European persons applying for
asylum increased drastically throughout all EU12 and EU15 (at the time) Member States. The
majority of asylum seekers came from countries affected by political intolerance, ethnic conflicts
and civil or international wars. Accordingly, the main regions of origin were Latin America (Chile,
Columbia, Ecuador), Africa (Ghana, the Republic of the Congo, Nigeria, Somalia), the wider
Middle East (Palestine, Iraq, Iran, Algeria, Morocco) and Asia (Socialist Republic ofVietnam, Sri
Lanka, Afghanistan).
As a response to the constant rise in the number ofasylum applications, bythe mid-1990s some
European countries had made the relevant regulatory frameworks and assessment criteria more
restrictive. Germany, for example, has changed the respective article in its Constitution with a view
to reducing the numbers of asylum seekers that selected Germany as their destination-country.
This change has made provisions for asylum seekers who are legally identified as being from 'safe
countries' to be returned to their country of origin. Changes in asylum-seeker reception policies in
some countries have also resulted in the partial shift of asylum applications to other destinations.
Thus, there is currently an increasing trend for asylum applications in Poland and other Central and
Eastern European countries from Chechen refugees, for instance.
The pathway oftemporary and seasonal migration
Temporary migration programmes have also been a permanent feature of migration regimes. The
recruitment programmes of the 1960s were planned and propagated as temporary programmes,
although not administered accordingly, and resulted in the settlement ofrecruited workers. After the
recruitment stopped in the early 1970s, temporary programmes were used with greater reluctance
in many countries. However, with the implosion of the communist regimes in 1989 in Central
and Eastern Europe and the liberalization of population flows that resulted, older programmes
increased in scope or new temporary programmes were introduced in order to find a legal way to
respond to the pressure of migration.
Temporary immigrants from non-EU countries have responded to the structural imbalance
of developed economies in Europe. They have occupied specific niches in the secondary labour
market, becoming cleaners, home carers, construction workers and generally filling jobs in the
lower-skilled, more labour-intensive and volatile sectors of the economy. Seasonal migrants have
been a similar case, accepted mainly for jobs in agriculture and tourism or catering services.
Temporary and seasonal recruitment programmes have been adopted by several EU countries
(including for instance Austria, France, Cyprus, Greece, Italy, Germany and the UK). The aim was
to provide a legal path for migrants to enter these countries and fill positions that were not taken by
natives because they were low-pay, low-prestige jobs with difficult working conditions. Whether
these temporary and seasonal labourers have remained temporary sojourners or have legally or
illegally converted into long-term migrants is a question only half explored.
The 'gold collar 'pathway
During the last 15 years there has also been increasing temporary and permanent immigration of
highly qualified professionals such as managers, investors and business persons, researchers in
academia and industry, engineers in multinational companies, sport professionals and people in the
arts in the western and southern EU countries. This migration occurs to a lesser extent in the new
Member States in the east. Immigration law often provides for preferential treatment for highly
qualified people and even when there are no such provisions in the law, implementation practices
Concluding Remarks 371
tend to be different when it comes to multinational company employees or highly qualified
professionals. This group is also referred to as 'knowledge migrants' in the Netherlands.
Although some highly qualified migrants have received particular media attention and have
used their position to defend the cause of other immigrants, the majority of these migrants seem
to be largely invisible and are not considered part of the immigration issue. In recent years, the
discourse in many countries has had a tendency to actively address the issue ofattracting this 'goldcollar'
immigrant labour force. It is perceived to be a major challenge for developed economies
(especially of the larger EU Member States such as Germany, France and the UK) to attract and
keep a part of this highly qualified, multilingual, internationally mobile cosmopolitan elite, in
order to enhance the knowledge-based competitiveness of their economy. The UK for example
has created the Innovators immigration category since 2000 to encourage the immigration of
innovative entrepreneurs, and the Highly Skilled Migrant Programme since 2002 to supplement
its labour market needs (European Commission, 2006, pp. 17-18). Numerically speaking, this
pathway involves a rather limited number of immigrants in Europe today.
The pathway ofirregular migration
A large percentage of new immigrants in EU countries are undocumented. Owing to either the
gradual establishment of restrictions on migration or the absence of an appropriate migration
policy, a proportion of the immigrant population currently has or has had an irregular or illegal
status. Some have entered host countries illegally; others have entered with a valid visa or residence
permit and have overstayed or abused their visa. Depending on the control regime ofthe receiving
country, some undocumented migrants may only work in unregisteredjobs in the shadow economy,
whilst others may work in registered jobs. While old host countries generally reject regularization
campaigns as an option and react with further internal controls to curb irregular migration, recent
host countries have made regularization or the so-called 'amnesty' programmes their main axis of
immigration policy. Gaps in the regularization laws, inefficient public bureaucracies, and the lack of
incentives for employers to ensure or facilitate the legal status ofmany migrants have complicated
the situation. This has led to the perpetual revitalization of this pathway, which is constantly refuelled
by new irregular immigration or where migrants live in limbo, shifting frequently between
legal and illegal status. In effect, a common story of many third -country nationals falling into
this category involves illegal entry, later regularization of their status but, often, the inability to
retain official status when their permit is due for renewal, for a variety of reasons ranging from
lack of a proper work contract (that is full, formal employment with social security benefits, and
so on) to not satisfying other requirements (for example, they risk bringing their family to the host
country even if their family reunification application is rejected because their taxed income is
not sufficient). This contributes to the marginalization and exploitation of a significant part of the
immigrant labour force.
Comparing integration policies and practices
A comparative examination of immigrant integration practices regarding naturalization regimes,
the granting oflocal voting rights and the extent ofimmigrant participation in the civic and political
life of the host countries presents a rather disjointed picture. Immigrants encounter very different
integration prospects and opportunities depending on the country in which they live, on the rights
that may be linked to their specific country of origin and to their individual status, as well as to the
implementation ofrights at the local level.
372 European Immigration
A full comparative overview ofthe conditions and regimes for immigrant integration in the EU
countries would go beyond the scope of our chapter. Therefore, we have chosen to address two
topics that, we believe, are of crucial importance for immigrant integration and that may also be
considered as emblematic ofthe 'integration philosophies' (Favell, 1998) currently present within
the Union. Thus, we discuss the naturalization options and the different types of migrant status
available to third-country nationals in the EU-25 and the question oflocal voting rights.
Naturalization and migration status regimes
All 25 EU Member States have participation regimes that distinguish between their own nationals,
EU citizens and third-country nationals. As a rule, only own-country citizens enjoy full political
and civic rights, while third-country nationals (non-citizens) are subject to different kinds of
restrictions. Within the immigrant population, however, there are also numerous distinctions,
depending on the status ofthe individual and the specific national group to which s/he belongs.
Most states have designed a variety of migration status levels for specific groups - temporary
workers, asylum seekers, family members of settled immigrants, immigrants with renewable
residence permits and permanent residents. Each type of permit may encompass a specific set of
rights which more or less deviates from.citizens' rights, andwhichchanges from country toco1mtry,
in spite of EU efforts (that is, the European Commission mainly) to define minimum.conditiQns.
While legal permanent residents sometimes enjoy full equality except for enfranchisement at
the national level, undocumented workers may be de facto excluded from all rights or may only
be allowed to access specific services such as emergency health care. Asylum seekers may be
restricted in their mobility in various ways ranging from detention and an obligation to live in
specified places, to being forbidden to leave a municipality or region.
Full political and civic rights and obligations may be acquired by immigrants from third
countries through the naturalization process. Most EU states primarily base citizenship on ancestry
(jus sanguinis) rather than on place of birth (jus soli), although most citizenship laws contain
elements ofboth. Member States also differ intheir acceptance ofdual citizenship and, hence, their
requirement for the migrant to abandon her/his citizenship of origin ifs/he is to naturalize.
The naturalization process is long and complicated in almost all countries, requiring a very long
list of documents that should accompany the application. Naturalization rules often also include
vague conditions that are open to different interpretations during their day-to-day implementation
by administrative personnel.
Eligibility for naturalization is basically defined on the basis of the length of stay. Other core
determining factors include language proficiency, good character, sound mind and no criminal
record. Acquisition ofcitizenship via marriage with a national ofan EU Member State is subject to
specific conditions, as are the procedures for refugees and asylum holders.
In practical terms this means that first-generation immigrants can request citizenship on the
basis oflength ofresidence in a country ofthe EU. Residence requirements vary between countries,
but also in relation to country of origin and residence status (for example, EU citizens, adopted
foreigners, refugees, stateless persons, non-EU citizens, and so on). Children born to immigrants
in the EU are usually considered to be 'foreigners', even though many EU Member States have
decreased residency and other naturalization requirements for 'second-generation' immigrants and
have extended automatic citizenship for the 'third generation'. In most EU countries, refugees and
foreigners with regular residence permits may request citizenship ifthey have permanently resided
in the territory ofthe country for periods of between five and ten years.
Ireland is exceptional, as it granted unconditional citizenship to all children born in Ireland
until2004. Since 2005, automatic rights to children of immigrants have been abolished unless one
Concluding Remarks 373
of the parents or grandparents has Irish citizenship or if the parent had been living in Ireland for
three of the four years preceding the birth of the child. On the contrary, Greece holds one of the
longest residence requirements in Europe. According to a policy which is currently under revision,
immigrants are required to reside in the country for ten out of the past twelve years in order to be
eligible for Greek citizenship.
In the CEE countries, the number of naturalizations was relatively high in the first half of the
1990s, reflecting mainly returning emigrants who had lost their citizenship while abroad. Since
2000, this number has been much lower. A specific situation was created in the newly formed
Baltic States and Slovenia, where immigrants from other regions of the former larger unit were
not granted citizenship. While there is some preferential treatment for gaining citizenship in the
Baltic States, in the case of Slovenia, no special provisions have been made to recognize the
sizeable community of citizens from other former Yugoslavian republics and war refugees who
have resided in the country for many years. Between 18,000 and 40,000 people were 'erased' from
the citizenship registers in the period immediately following national independence.
In Latvia and Estonia (but not in Lithuania) after the Restoration of Independence, all those
who were not citizens of the country in the pre-1938 period were declared aliens and had to apply
for naturalization. Requirements for the naturalization procedure included five years of residence,
a legal source ofincome, and a thorough knowledge ofboth the constitution and the state language.
Indeed, language became the main obstacle (and contested issue) for naturalization as these 'internal
migrants' from other parts ofthe Soviet Union were Russian speakers and had not needed, nor had
they been required during Soviet times, to learn the language of the country in which they settled.
While alienating some of their residents, the Baltic countries welcomed emigrants who wished to
return and who could prove their link to the country through their own or their parents' citizenship
ofthe pre-1938 states.
Most ofthe immigrants who arrived in Latvia and Lithuania during the Soviet period have now
been naturalized, but the situation is more difficult in Estonia. The annual number ofnaturalizations
has grown smaller, and the majority of the people who have received citizenship in recent years
have been children.
In fact, for many countries of Central and Eastern Europe, naturalization policies appear to
be more strongly shaped by concerns about expatriates, diasporas and ethnic kin minorities in
neighbouring countries than by immigration. It should be noted, however, that a number of older
EU Member States, have also long pursued policies ofpreferential access to citizenship for persons
who are considered ethnic or linguistic relatives. This is the case for Germany, Portugal, Spain,
Italy and Greece. Germany awards German citizenship immediately to ethnic Germans from the
former Soviet Union who have been accepted as co-ethnics in the application procedure, as does
Greece with Pontic Greeks from the former Soviet Republics. Spain reduces the ten-year legal
residence requirement for naturalization to two years for persons from countries that hold special
cultural and historic bonds with Spain such as Andorra, the Philippines, Equatorial Guinea and
most Latin American countries. Portugal also has a preferential regime for Portuguese-speaking
countries, since PALOP nationals require a minimum of a six-year residence permit to be eligible,
whereas a minimum often years is required for other third-country nationals.
The different migrant status and naturalization regimes of each country result in different
distributions between nationals and non-nationals in each country. In other words, in some countries
a large part ofthe migrant population has naturalized and disappeared from the migration registers.
Sweden is illustrative of this, where approximately half of all foreign-born persons residing in the
country for five years or more become Swedish citizens. In other countries, even second- or thirdgeneration
migrants remain aliens: Some countries continue to keep a record of their naturalized
374 European Immigration
foreigners and/or generally oftheir population that has some foreign ancestry (for example France
and the Netherlands) while other countries do not (for example Germany and the UK).
Local voting rights
We have chosen to discuss local voting rights here as these are the most advanced political right
conceded to non-nationals in some countries. While voting in national elections remains the
privilege of citizens,6
some countries have offered to third-country nationals the possibility to
vote and also stand for office in local elections. More specifically, there are three variations of this
policy: the denial ofvoting rights at the local level; the granting ofthe right to vote but not to stand
as a candidate in local elections; and the granting of full political rights, active and passive (see
table below).
Table 27.2 Voting rights for third-country nationals in EU Member States
Political rights
No local voting rights
Granting ofvoting rights but not of
the right to stand as candidate
EU Member States
Austria, Cyprus, Czech Republic, France,
Germany, Greece, Hungary, Italy, Latvia,
Lithuania, Luxemburg, Poland
Belgium, Estonia
Full voting rights at the local level conditional Denmark, Finland, Ireland, Netherlands, Malta,
to the fulfilment of special requirements Portugal, Slovakia, Slovenia, Spain, Sweden, UK
Source: Table 2 in Cyrus et al. (2006: 80); see also POLITIS project country reports (http://www.uni-
oldenburg.de/politis-europe/index.html).
Nearly half of the EU Member States belong to the first group ofcountries, those that do not grant
voting rights at the local level to their resident foreign population. Altogether 12 countries strictly
deny local enfranchisement. But the fact that these countries deny immigrant voting rights at the
local level does not mean that the issue is not part ofthe political debate. In those western countries
with a higher percentage ofimmigrant population, such as Luxembourg, Italy, Germany orAustria,
the introduction of voting rights for immigrants was at one moment or another a significant issue
on the political agenda. While the Government of Luxembourg did not even consider the matter,
legislators in some of the other countries took the proposal to enfranchise foreign residents more
seriously, though ultimately did not adopt relevant legislation. The case of Germany, with its
federal constitution, is illuminating. Here, some ofthe federal states had passed a law that foresaw
the voting right for resident non-EU nationals. However, the project was cancelled after a court
ruling by the Federal Constitutional Court in 1994, which underlined the fact that the right to vote
at every level of political decision-making is perceived to be the exclusive privilege of citizens.
The only way to acquire political voting rights is through the acquisition ofcitizenship.
Two countries, Belgium and Estonia, have introduced a reduced voting right at the local level
that gives resident non-EU citizens the right to vote but not to stand for elections. In the case of
6 With some small but notable exceptions related to each country's history (for example citizens of
Commonwealth countries in Britain).
Concluding Remarks 375
Belgium, where voting is compulsory for citizens, the enfranchisement of foreign nationals at the
local level was due to come into force for the first time in 2006. The main requirement is to maintain
a legal residence for at least five years. The regulation is a response to the claims of immigrant
associations and their supporters for local voting rights. In the case of Estonia, foreign citizens
and stateless persons - here the relatively large group of former Soviet citizens who lost their
citizenship with the formation of the Estonian nation-state - are entitled to vote in local council
elections ifthey hold a permanent residence permit and have resided legally on the territory ofthe
corresponding municipality for at least five years by January 1'' of the election year. However, the
right to stand as a candidate is reserved to Estonian citizens.
At the time of writing (2006) at least 11 EU Member States have enfranchised the resident
foreign population at the local level. Local voting rights were introduced in some countries several
decades ago (for example, Sweden, 1976; Denmark, 1981), while in other countries, foreign
nationals will enjoy local voting rights for the first time in forthcoming elections. All countries
require the observance of particular conditions that define the eligibility of non-EU citizens to
participate in local elections as voters or candidates. The most general requirements are legal status
of a minimum duration (usually five years) and that individuals have to register in order to vote.
In some countries enfranchisement is restricted to immigrants who hold the citizenship ofspecific
countries. A notable exception to these obligations is Ireland where, since 2004, third-country
nationals who are 'ordinary residents' have enjoyed full local voting rights from the first day of
their registration in the local register.
Three EU Member States have only enfranchised individuals from particular countries. In the
UK, citizens ofCommonwealth countries qualify to vote for local elections. In Spain and Portugal
only those citizens of countries which have signed a mutual agreement to grant local voting rights
can participate in local elections. In 1996, for example, Portugal introduced the immigrants' right
to vote and stand for election at the local level. However, only citizens from some countries are
entitled to this political participation (namely Argentina, Brazil, Cape Verde, Chile, Israel, Norway,
Venezuela, Uruguay and Peru) because enfranchisement is based on the principle of reciprocity
between states.
The granting of voting rights does not appear to be influenced by the size of the immigrant
population, norby its composition. It is not subjectto how maturethe migration history ofthe Member
State is, although long experience with migration seems to encourage local enfranchisement. Local
voting rights are partly related to post-colonial ties. Also, states with a strong ethnic or national
element tend to be in the group that denies local voting rights, even though there is a certain trend
towards local enfranchisement of immigrants in the European Union.
Final remarks
This chapter has provided a comparative overview ofimmigration in the EU-25. More specifically,
we have proposed a typology of countries based on their migration experience during the last
decades. We have thus distinguished between old hosts, recent hosts, countries in transition, small
island countries and non-immigration countries. We have also constructed a typology ofmigration
pathways, that is, sets of opportunities, policies, motivations and constraints that open a specific
channel where people and information flow more easily and more intensely than when these
conditions are not in place. The notion of migration pathways is tentatively introduced here. Its
scope or usefulness needs to be developed further in empirical research (see also Psimmenos and
Kassimati, 2003). Our two typologies aim at providing a broad description ofmigration phenomena
and a first attempt at creating up-to-date theoretical classifications that respond to contemporary
376 European Immigration
European realities. The last section of this chapter has given some brief insights into two main
issues of immigrant integration, notably the question ofnaturalization and the issue oflocal voting
rights. These are only two among several important contested issues that European Union countries
need to address ifthey are to respond to the challenge ofmigration for the twenty-first century. We
believe that this book is an important first step in the systematic exploration and comparison of
contemporary European migration. Further comparative research is needed to develop the field of
comparative migration studies, highlighting the similarities and differences between the EU-25 as
regards migration and migrant integration.
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