Citizenship and Nationhood in France and Germany

Rogers Brubaker

• Publisher: Harvard University Press
• Year: 1998
• ISBN:
  9780674252998
• Topic: Storia
• Subtopic: Storia francese

The difference between French and German definitions of citizenship is instructive—and, for millions of immigrants from North Africa, Turkey, and Eastern Europe, decisive. Rogers Brubaker shows how this difference—between the territorial basis of the French citizenry and the German emphasis on blood descent—was shaped and sustained by sharply differing understandings of nationhood, rooted in distinctive French and German paths to nation-statehood.

II

DEFINING THE CITIZENRY: THE BOUNDS OF BELONGING

4

Citizenship and Naturalization in France and Germany

Citizenship, we have seen, is inherently bounded; it is everywhere an instrument and object of social closure. Yet the bounds of belonging are drawn differently in different polities. This was true in ancient Greece where, as Aristotle observed, “the man who is a citizen in a democracy is often not one in an oligarchy.”¹ And it remains true in modern Europe, where the immigrant who would be a citizen in France would often not be one in Germany—unless he happened to be of ethnic German origin. The rate of civic incorporation for migrant workers and their descendants is more than ten times higher in France than in Germany. And the gap is even greater for second- and third-generation immigrants. A generation of young Franco-Portuguese, Franco-Algerians, and Franco-Moroccans is emerging, claiming and exercising the rights of French citizenship. In Germany, by contrast, nearly half a million second-generation Turkish immigrants, born and raised in Germany, remain outside the community of citizens.

The sharply differing definitions of citizenship are particularly striking in view of the similar French and German experiences with migrant labor in the last quarter-century.² In both countries foreign workers were recruited in large numbers in the 1960s and early 1970s in response to labor shortages. Organized recruitment was suspended in 1973–74, partly in response to the oil shock and ensuing recession, partly in response to the growing concern about the social and political consequences of large-scale immigration. Nonetheless, populations of immigrant origin have continued to grow in both countries, largely through family reunification.

Immigrants in both countries have become dramatically more visible in everyday life during the last two decades. During the 1950s and early 1960s most foreign workers were either single or separated from their families. Many lived in isolated workers’ hostels. Outside the workplace they were largely invisible, participating little in the social, cultural, or political life of the host society. In the last two decades, however, the sojourners have become settlers. Single workers were joined by their families, or formed new families. Immigrants became neighbors, school-mates, and joint users of public spaces. An increasingly vocal second generation emerged, tenuously rooted in the culture of the parents’ generation, yet economically and socially marginalized in the country of residence. Groups marked by dress, language, religion, and custom as “culturally distant” comprised the fastest-growing segment of the immigrant community. Immigrants in both countries have clustered in particular regions and, within cities, in particular neighborhoods.³ All these developments made immigrants much more visible.

In both countries immigrants comprise a substantial fraction of the manual working class and are overrepresented in dirty, dangerous, unpleasant, ill-paid, and menial occupations. They are also overrepresented among the unemployed. As a relatively young group, with comparatively high fertility rates, immigrants play a similar demographic role in France and Germany, which share concerns about low fertility and aging populations. This has implications for the labor market, the social security system, and, in the longer run, for military conscription—if peacetime conscription survives the great geopolitical reconfiguration now under way.

Discourse about immigration and immigrants follows similar patterns in both countries. There is an inclusionary discourse that stresses the economic and cultural contribution of immigrants to the host society and the values of tolerance and diversity. And there is a counterdiscourse stressing the unassimilability of immigrants, the dangers of excessive cultural heterogeneity, the social strains and economic costs of immigration, and the prospect of Islamic fundamentalism and interethnic strife. Finally, there are striking similarities in immigration policies. Since the mid-1970s all French and German governments, left and right, have pursued the same threefold policy, seeking to impose strict limits on further immigration, to encourage voluntary return migration, and to facilitate the integration of second-generation immigrants.⁴

There are of course significant differences between French and German experiences with immigration. Many immigrants to France have come from former French colonies and protectorates, while immigration to Germany has lacked this colonial connection. Both countries have been concerned with undocumented immigration and with an upsurge in the number of persons seeking political asylum, but the French have been particularly preoccupied with the former, the Germans with the latter. Jean-Marie Le Pen’s National Front has fared much better in France than any far-right xenophobic party in Germany. France is particularly concerned about migration from the south, from the Maghreb and sub-Saharan Africa, Germany about migration from the east, especially from Poland and the ex-Soviet Union. And since the massive exodus thirty years ago of colonial settlers from postindependence Algeria, there has been no French analogue to the great migration of ethnic Germans from Eastern Europe and the Soviet Union, which brought over a million immigrants to Germany between 1988 and 1991.

Patterns of Naturalization and Definitions of Citizenship

Despite these differences, the overall picture is one of similar migration processes, comparable immigrant populations, and converging immigration policies. In the context of these thoroughgoing similarities, the sharply differing policies and politics of citizenship stand out as a striking anomaly. In the first place, German naturalization policies, although recently liberalized, remain more restrictive than those of France. Ten years’ residence is ordinarily required in Germany, five years in France. More important, candidates for naturalization must ordinarily renounce their original citizenship in Germany, but not in France.⁵ Besides these specific differences in requirements, there are more general differences in attitudes toward naturalization. Germany lacks a political culture supportive of naturalization. This is clearly expressed in the administrative regulations governing naturalization, which state unambiguously that “the Federal Republic is not a country of immigration [and] does not strive to increase the number of its citizens through naturalization.”⁶ In countries of immigration like the United States and Canada naturalization is expected of immigrants; the failure to naturalize is anomalous. In France too, which alone in Continental Europe has a tradition of immigration for purposes of permanent settlement, naturalization has been considered the normal and desirable outcome of permanent settlement. In German self-understanding, by contrast, one cannot join the nation-state by voluntary adhesion (the North American model) or state-sponsored assimilation (the French model).

Immigrants’ attitudes toward naturalization, moreover, differ in France and Germany. In 1985 only 6 percent of German migrant workers and family members, and 9 percent of those aged fifteen to twenty-four, intended to naturalize, while about a quarter of young foreigners in France intend to become citizens.⁷ The very low propensity to naturalize among German immigrants, many of whom clearly would qualify for naturalization, reflects a desire to retain their original citizenship.⁸ Beyond this, though, the differential interest in naturalization may reflect different understandings of what naturalization means in France and Germany. To a greater extent in Germany than in France, it appears, naturalization is perceived as involving not only a change in legal status, but a change in nature, a change in political and cultural identity, a social transubstantiation that immigrants have difficulty imagining, let alone desiring. Evidence of this blurring, in the minds of immigrants, between legal citizenship and a richer, more diffuse notion of ethnocultural nationality can be found in France as well. In France, however, a larger fraction of the immigrant population seems to have adopted a more instrumental, “desacralized” understanding of citizenship, seems to have divorced the legal question of citizenship from broader questions of political loyalty and cultural belonging.⁹

These differences in policies and attitudes toward naturalization are reflected in naturalization rates that are four to five times higher in France than in Germany for the main groups of migrant workers and their dependents (see Tables 1 and 2).¹⁰ Italians naturalize at rates five times higher, Spanish at rates ten times higher in France than in Germany. And Tunisians and Moroccans in France naturalize at rates nearly ten times higher than that of Turks in Germany. Of the 1.5 million Turks in Germany, over 1 million of whom have resided there ten or more years, and more than 400,000 of whom were born there, only about 1,000 acquire German citizenship each year. Even if rates increased tenfold, naturalizations would still be far outweighed by the 25–30,000 new Turkish citizens born each year in the Federal Republic.¹¹

The German government has been saying since the mid-1980s that it favors the naturalization of second-generation immigrants, observing that “no state can in the long run accept that a significant part of its population remain outside the political community.”¹² And in 1990 the legal provisions governing naturalization were liberalized for persons brought up in Germany and educated at German schools, as well as for persons having resided more than fifteen years in Germany.¹³ Over time, a modest increase in naturalization rates is to be expected as the immigrant population becomes increasingly settled. Yet patterns of naturalization are unlikely to change dramatically. The most important obstacle to naturalization—the requirement that candidates give up their original citizenship—was not touched by the 1990 reform. Moreover, the barriers to naturalization lie not only in the restrictiveness of legal provisions but equally in the political culture of naturalization, embodied in attitudes of Germans and immigrants alike. Without a changed understanding of what it is to be—or to become—German, the liberalization of naturalization policy will not produce a dramatic surge in naturalization.

Table 1. Naturalizations in France by original citizenship, core immigrant groups, 1981–1989.

Source: Recensement Général de la Population de 1982, Les étrangers (Paris: La Documentation Française, n. d.), pp. 20, 106; Journal Officiel, Assemblée Nationale, Débats parlementaires, Nov. 3, 1986, pp. 4019–4021, Written questions, response to questions no. 4033 and 10393; Sous-Direction des Naturalisations, Direction de la Population et des Migrations, Ministère des Affaires Sociales et de la Solidarité, Annual Reports, 1984–1989; Annuaire Statistique de la France (Paris: Institut National de la Statistique et des Etudes Economiques, 1990), p. 87.

a. This includes acquisitions of citizenship by declaration on the part of spouses of citizens and French-born children of foreign parents. Since the breakdown of such declarative acquisitions by original citizenship has been available only since 1984, the figures in this column, and the rates in columns D and E, represent the 1981–1989 annual averages for discretionary naturalizations plus the 1984–1989 averages for declarative acquisitions. Column C also includes “reintegrations,” meaning reacquisitions of French citizenship on the part of persons formerly possessing it and subsequently having lost it. This category is significant for Algerians, accounting for 52 percent of all voluntary acquisitions of nationality by Algerians between 1985 and 1989; but it is negligible for all other core immigrant groups.

Naturalization rates, then, are four to five times higher in France than in Germany. But patterns of civic incorporation diverge even more sharply than this suggests. It is not enough to consider the voluntary acquisition of citizenship by naturalization or individual declaration. We must also consider the attribution of citizenship by the state. Naturalization patterns and policies must be understood in conjunction with the rules specifying whom states unilaterally define as citizens. Working invisibly and automatically, independently of the will—and sometimes even the knowledge—of the persons concerned, the rules governing the ascription of citizenship have been all but ignored by the meager literature on immigration and citizenship. Yet they are more important than naturalization rules in shaping patterns of civic incorporation in France and Germany. Ascription constitutes and perpetually reconstitutes the citizenry; naturalization reshapes it at the margins. The striking difference in the civic incorporation of immigrants in France and Germany is chiefly a consequence of diverging rules of ascription. Differing naturalization rules and rates reinforce this difference but are not its fundamental source.

Table 2. Naturalizations in the Federal Republic of Germany by original citizenship, core immigrant groups, 1981–1988.

Source: Heinrich Meyer, “SOPEMI 1986. Federal Republic of Germany” (Organization for Economic Co-operation and De...