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Britain has traditionally been a country of emigration. Since the eighteenth century considerable numbers of Britons have moved overseas and helped establish and populate the United States and countries of the British Commonwealth and Empire. During the nineteenth century the majority of migrants went to the USA, but after 1900 most emigrated to Canada, Australia, and other Commonwealth countries. By the turn of the century migration had become a conscious part of British imperial policy, and it was felt that encouraging emigration from Britain to the Commonwealth would help the economic development of Dominion territories, strengthen the ties with Britain, and increase the power of the Empire. Land grants and assisted passages were used to encourage people to migrate. After the First World War the self-governing Dominions became more selective in their demands for migrants, requiring skilled industrial workers instead of agricultural workers. There was no halt in the outward flow, however, and between 1919 and 1930 two million people emigrated from the United Kingdom.
The depression between the wars caused a change in the balance of migration and the net flow became an inward one. After the Second World War, however, emigration resumed at a high level, encouraged particularly by the immigration policies of Australia, which was concerned to increase her population for security reasons and also to maintain its British character. Between 1946 and 1950 720,260 people left the UK, and most of them were relatively highly skilled (Cheetham 1972).
For many years the Netherlands has had a reputation for its strong international orientation. The country's favorable geographical location enabled it to become the seafaring nation of Europe. In order to insure commercial contacts it built up a colonial empire of surprising dimensions, given the modest size of the mother country. Since the Reformation in the sixteenth century the Netherlands has also been known as a tolerant country, and it became a refuge for those who were persecuted on grounds of religious or political beliefs. Jews from all over Europe, Huguenots from France, Roman Catholics from Germany, and many other refugees have contributed substantially to the country's economic prosperity and cultural development. During certain periods there was also a substantial immigration of temporary and permanent workers from nearby countries. Many of these were employed in agriculture, while others served as mercenaries in the navy and the army.
On the other hand, commercial and other interests in many parts of the world have led to substantial emigration. Dutch people have settled in many former colonies (North America, Brazil, West Africa) and in some cases their descendants may still be traced quite easily (Burghers in Sri Lanka, Boers in South Africa). During the nineteenth century large groups of Dutch emigrants moved to the United States and to the former Netherlands East Indies. Since the Second World War, and especially during the 1950s, half a million people have left for “New World” countries like Canada, Australia, and New Zealand.
France has a long tradition of immigration. Since the second half of the nineteenth century thousands of foreigners have been recruited or granted admission in an effort to compensate for the country's insufficient labor supply and low birthrate. The low birthrate has created a permanent demographic need and has together with periodic labor shortages served to motivate immigration. Immigration policy has tried to regulate the arrival, residence, and departure of foreign workers and their families, according to the interests of the moment.
The effects of immigration policy, however, have never been exactly those expected or planned for. When French governments wanted immigrants to come, as in 1919 and 1945, only a few responded; when they tried to send them home, as in 1932 and 1978–79, only a small number cooperated, and many chose to be naturalized instead. The two periods of heavy immigration, 1921–31 and 1956–72, escaped the control of political authorities almost totally. Today, illegal workers are still entering France despite firm border controls and generally increasing unemployment. “In spite of the efforts undertaken by the international organizations and by concerned governments, on a worldwide scale spontaneous migrations are rather the rule and organized migrations the exception” (Costa-Lascoux & de Wenden-Didier 1981:352).
In Table 5.1 immigration policy appears as only one of the regulating elements. Immigration reaches its peaks when employers want to augment the insufficient supply or avoid the excessive cost of domestic labor by replacing it with available and cheap foreign labor.
We have observed a divergence in immigration policy during the period of large-scale labor immigration. The industrialized states of Western Europe made similar economic gains, but they differed in immigration policy, since their preconditions of immigration were in many respects markedly different, and since some states mainly admitted colonial immigrants, while others relied on recruitment of foreign labor.
In this final chapter, we will argue that policy divergence has come to an end; instead, there is now a trend towards policy convergence. In fact, this trend started when recruitment of foreign labor was terminated at the beginning of the 1970s, at what we have called the turning point. But this does not mean that most differences between the project countries' immigration regulation have disappeared, nor that immigrant policy has assumed one and the same form everywhere. The implication is only that a slow and continuous shift in policies has brought the six project countries closer to one another than before. Discussion of a number of explanations for this convergence will allow us to sum up some of the major conclusions from previous chapters. In a short diversion, the immigration policy of the United States will then be compared to the European experiences, and finally, some recommendations will be offered, based on the comparative analysis.
Considering its economic capacity Switzerland was long overpopulated. The problems arising from this situation were dealt with by the systematic promotion of emigration. Military emigration, i.e. enlistment as mercenaries, was the preferred form of emigration, and it had become institutionalized by the sixteenth century. Between 300,000 and 350,000 mercenaries emigrated from Switzerland in the eighteenth century (Bickel 1947:91).
Compared with the huge emigration of this period, immigration was of little importance. The only significant immigration resulted from religious persecution in neighboring countries. Between 100,000 and 150,000 Huguenots rushed to Switzerland after the revocation of the Edict of Nantes (1685), but only about one tenth remained there permanently (Bickel 1947:88,106f; Ludwig n.d.:14). Civil immigration never came close to military emigration in importance; only 40,000–50,000 persons immigrated in the eighteenth century, a time when Switzerland's total population was 1.7 million (Bickel 1947:50,99). The main reason for this low immigration rate was probably that Switzerland had little economic attraction at the time. In addition, the extremely restrictive immigration policy of the cantons and communities, which tried to keep out even other Swiss, may also have played a role (Bickel 1947:102; Langhard 1913:3f).
In the first decades of the nineteenth century Switzerland had no centralized immigration policy. A short phase of leniency during the Helvetic Republic (1799–1802) and the Mediation Period (1803–14) was followed in 1815 by a return to the extremely restrictive policy of the eighteenth century (Moser 1967:331).
This chapter discusses how immigration policy is made. Unlike the previous chapters, here we are interested in the origin and form of policy rather than in its content. Though all six of the project countries are democracies where two or more parties compete in free elections, each is governed in a different fashion and has its own particular kinds of institutions and traditions. The parliamentary system of Britain stands in contrast to the presidential system of France; the centralized French system of decisionmaking stands in contrast to the decentralized Swiss system, with its autonomous cantons and local authority, as well as to the federal system of Germany; the multiparty system of the Netherlands stands in contrast to the traditional two-party system of Britain. Despite these considerable differences in political systems, however, there are significant similarities in how immigration policy is made. This chapter will examine those similarities.
Policy or “non-policy”
German politicians have emphatically declared that their country is not a country of immigration. This declaration comes as somewhat of a surprise to foreign observers, who note that approximately four million foreign citizens reside in the Federal Republic. The Germans have answered that these foreign citizens, originally recruited as labor, should be regarded as temporary “guestworkers”; in other words, no plans have ever been made in Germany for permanent immigration. The number of foreign workers has become large only because the economy required extra manpower during a period of transition.
Immigration regulation is the control that a sovereign state exercises over the entry of foreign citizens and their access to residence and employment. As mentioned previously, most countries in Western Europe developed organized systems of immigration regulation at around the same time in the early 1900s. During periods of severe unemployment in the 1920s and 1930s, immigration control was strictly applied in protection of the national labor market. But we have seen that a new period of economic liberalism followed after the Second World War, once more liberalizing immigration control and opening the way for a great increase in labor migration.
Since aliens laws entrusted administrative bodies with great discretionary powers, it was not necessary in most countries to make amendments to these laws each time a more strict or a more liberal immigration regulation was introduced. What was needed was only a change in the application of existing provisions of the laws. But in Britain new legislation was continuously introduced in order to limit the size of colonial immigration.
In this chapter we shall compare regulation both before and after the turning point in the early 1970s, and discuss what kind of regulation has been used in countries with guestworker systems and in those countries with a system of permanent immigration. We shall also ask why Germany has not been willing to acknowledge a large, de facto permanent immigration, and why Sweden has not applied a guestworker system.
During the twentieth century, immigration policy has progressed along similar lines in all of the project countries. Though their modern political histories differ in many respects, they have all been affected by the two world wars, and by the same long-and short-run economic trends. This shared experience is fundamental for any comparison of our six immigration countries.
As countries with at least de facto immigration, they may affect each other through their policy decisions. If, for instance, one state closes its borders, potential immigrants may try to be admitted to a neighboring state instead, which then experiences more immigration and may react with stricter controls or perhaps even close its borders completely. Immigration countries may make use of techniques already applied in other countries, such as the manipulation of residence and work permits or the alteration or enforcement of legislation concerning deportation or citizenship. The six countries studied are thus not independent cases, for the simple reason that they establish and implement their immigration policy under the same economic and political conditions and under the influence of the same prevailing ideologies.
Liberalism and nationalism
From the middle of the nineteenth century until the First World War two ideologies of great importance for international migration existed uneasily side by side: economic liberalism and political nationalism. Great Britain was the standardbearer of liberalism and led the way in 1846 with a systematic free-trade policy.
In many respects the present situation in Germany in regard to immigration and immigrants is unprecedented. A great number of immigrant families are preparing for a permanent stay and some form of “integration”; moreover, easing the tension between integration and cultural autonomy is being considered on a political level. The situation now differs fundamentally from that of the past, when foreign workers were either clearly defined as seasonal workers and subjected to rigid Germanization during their stay (and in the Second World War forced into war production) or else used as an easily transferable labor pool to compensate for manpower shortages in certain branches of the economy. Yet policymakers have found it difficult to grasp this difference and to act accordingly, which is why the current reorientation of immigration policy has been so difficult.
To understand the novelty of the present situation and to appreciate the obstacles faced in changing from a “guestworker” policy to an “immigration” policy, one must begin by examining the varied history of population movements and foreign labor migration into the German Reich and the Federal Republic of Germany (FRG).
Until 1885 Germany was mainly an emigration country (Armengand 1971:163fT). Germans emigrated primarily to the United States and, to a lesser extent, to Canada, Australia, and South America. A number of Germans settled down to work as administrators and merchants or founded new settlements in the Baltic, Poland, and Russia.