Verffentlichungsreihe der Abteilung ffentlichkeit und

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Wandel, Institutionen und Vermittlungsprozesse des
Wissenschaftszentrums Berlin fr Sozialforschung

FS III 97-101

Citizenship, National Identity and the Mobilisation

of the Extreme Right. A Comparison of France,
Germany, the Netherlands and Switzerland

Ruud Koopmans and Hanspeter Kriesi

Berlin, Mrz 1997

Wissenschaftszentrum Berlin fr Sozialforschung gGmbH (WZB)

Reichpielschufer 50, D-10785 Berlin

Telefon (030) 25 491-0

Zilierweise:
Ruud Koopmans and Hanspeter Kriesi, 1997:
Citizenship, National Identity and the Mobilisaiton
of the Extreme Right.
A Comparison of France, Germany, the Netherlands
and Switzerland.
Discussion Paper FS III 97-101.
Wissenschaftszentrum Berlin.
Abstract

In trying to account for cross-national differences in the strength of the extreme right in
four West European countries - France, Germany, the Netherlands and Switzerland - this
paper combines theories of citizenship and national identity with recent developments in
the literature on social movements. Regarding conceptions of citizenship and nationhood,
we distinguish two dimensions: (1) on the formal, legal level, one can differentiate bet-
ween countries with ethnic (ius sanguinis) and those with civic (ius soli) definitions of
citizenship; (2) with regard to the cultural obligations tied to citizenship we distinguish
between exclusive models that exert strong pressures towards assimilation of cultural
difference and inclusive models that tolerate or even stimulate cultural heterogeneity.
Combining opportunity and framing perspectives on social movements, these different
conceptions of citizenship and national identity are seen as discursive opportunity
structures that delimit the range of legitimate and "credible" discourses to which collecti-
ve actors must relate in order to be succesful with their framing and mobilisation efforts.
For the extreme right this implies that its mobilisation and success chances will be facili-
tated or constrained depending on the specific dominant discourse on citizenship and na-
tionhood it confronts. In the empirical part of the paper, these ideas are applied in an
analysis of the interdependence between dominant and challenger discourses in the four
countries. The results indicate that the substantive success of the extreme right in the
form of restrictive immigration and citizenship policies tends to be greatest in countries
with an ethnic-exclusivist tradition such as Germany, and most limited in countries such
as the Netherlands which adhere to a multicultural model. However, in terms of the level
of mobilisation, measured by the electoral strength of extreme right parties, the extreme
right tends to be strongest in the two countries, Switzerland and France, that combine
inclusive and exclusive elements. We argue that the contradictions and tensions within
the dominant discourse and concomitantly also within the political elite of these countries
offer particularly favourable opportunities to the extreme right, which on the one hand
can draw legitimacy and credibility from the more exclusive elements of accepted dis-
course, while simultaneously pre-emption - which is typical for the German case - is pre-
vented by its opposition to other parts of the countries' immigration and citizenship poli-
tics. We finally discuss the implications of our findings for the future of citizenship and
immigration politics, both nationally and on the European level.
Zusammenfassung

In diesem Papier wird versucht, die unterschiedliche Strke der extremen Rechten in vier
westeuropischen Lndern - Frankreich, Deutschland, den Niederlanden und der
Schweiz - durch eine Kombination von Theorien zur Staatsbrgerschaft und nationalen
Identitt auf der einen und neueren theoretischen Entwicklungen in der Literatur zu so-
zialen Bewegungen auf der anderen Seite zu erklren. Im Hinblick auf die Konzeption
von Staatsbrgerschaft und nationaler Identitt unterscheiden wir zwei Dimensionen: (1)
Auf der formellen, juristischen Ebene kann man zwischen Lndern mit einer ethnischen
(ius sanguinis) und solchen mit einer zivilen (ius soli) Definition der Staatsbrgerschaft
differenzieren. (2) Was die kulturellen Anforderungen, die mit der Staatsbrgerschaft
verknpft sind, anbelangt, so kann man zwischen exklusiven Modellen, die einen starken
Assimilationsdruck ausben, und inklusiven Modellen, die kulturelle Vielfalt tolerieren
oder sogar frdern, differenzieren. Durch die Anwendung einer Kombination von
"opportunity" und "framing" Perspektiven auf soziale Bewegungen knnen solche unter-
schiedlichen Konzeptionen von Staatsbrgerschaft und nationaler Identitt als diskursive
Gelegenheitsstrukturen betrachtet werden. Diese definieren die Grenzen des legitimen
und "glaubwrdigen" diskursiven Raumes, zu dem kollektive Akteure sich, wollen sie bei
ihren Mobilisierungs- und Deutungsversuchen erfolgreich sein, verhalten mssen. Fr die
extreme Rechte bedeutet dies, da ihre Mobilisierungs- und Erfolgschancen vom jeweils
aktuellen Diskurs ber Staatsbrgerschaft und nationale Identitt erweitert bzw. einge-
schrnkt werden. Im empirischen Teil des Papiers werden diese theoretischen Annahmen
einer Analyse der Interdependenz zwischen dominanten und herausfordernden Diskursen
in den vier Lndern zugrunde gelegt. Die Ergebnisse deuten darauf hin, da inhaltliche
Erfolge der extremen Rechten in der Form restriktiver Einwanderungs- und Staatsbr-
gerschaftspolitik am strksten in Lndern mit einer ethnisch-exklusiven Tradition wie
Deutschland und am schwchsten in Lndern mit einem multikulturellen Modell wie den
Niederlanden nachzuweisen sind. Demgegenber erzielte die extreme Rechte ihre gr-
ten Mobilisierungserfolge, gemessen an den Wahlergebnissen rechtsextremer Parteien, in
Frankreich und der Schweiz, den beiden Lndern, die inklusive und exklusive Elemente
kombinieren. Aus unserer Sicht sind es gerade die Widersprche und Spannungen inner-
halb des dominanten Diskurses und entsprechend auch innerhalb der politischen Elite die-
ser Lnder, die besonders gnstige Mobilisierungschancen fr die extreme Rechte bieten.
Auf der einen Seit kann die extreme Rechte durch ihren Anschlu an exklusive Elemen-
te des gngigen Diskurses Legitimation und Glaubwrdigkeit gewinnen. Zugleich ist,
wegen der institutionellen Verankerung inklusiver Elemente der Staatsbrgerschaft, die
fr Deutschland kennzeichnende Strategie der "preemption", in der die politische Elite
einem potentiellen Mobilisierungsdruck der extremen Rechten durch eine restriktivere
Einwanderungspolitik zuvorkommt, in diesen Lndern eine deutliche Grenze gesetzt.
Zum Schlu werden die Implikationen der Befunde fiir zuknftige Entwicklungen der
Einwanderungs- und Staatsbrgerschaftspolitik sowohl auf der nationalen als auch auf
der europischen Ebene diskutiert,
 Citizenship, National Identity and the Mobilisation
of the Extreme Right. A Comparison of France,
Germany, the Netherlands and Switzerland

Ruud Koopmans and Hanspeter Kriesi

1. Introduction

National and ethnic bonds, long thought to be withering away in the process of moder-
nization, have recently regained importance as bases for collective identities and mobi-
lization. In Western Europe, this development has taken the form of an increased politi-
cizalion of the issue of immigration and the rise of xenophobic and extreme right actors
on the political stage. The social sciences have dealt with these developments in the fast
expanding literatures on nationalist and xenophobic movements on the one hand, and on
conceptions of nationhood and citizenship, on the other. In this paper, we would like to
try to combine these two perspectives and discuss the relations between different con-
ceptions of citizenship and nationhood and the ethnocentric mobilization of right-wing
extremists. Our discussion will be exploratory and tentative. Our perspective in this
discussion is comparative and we shall try to compare the situation in the four Western
European countries - France, Germany, the Netherlands and Switzerland - for which we
have already analyzed political mobilization in a previous study (Kriesi et al. 1995). This
study focussed on the role of so-called political opportunities for the mobilization of
social movements (see also McAdam 1982, Tarrow 1994). In applying this approach to
the extreme right our guiding idea is that the level of mobilization and the success chan-
ces of xenophobic movements are shaped by external constraints and opportunities de-
fined by nationally specific institutional structures and political cultures. In the present
study, we will selectively focus on nationally specific conceptions of citizenship and na-
tional identity as one aspect of political opportunity that seems particularly important for
 8

the mobilization of the extreme right. In doing so, we do not claim that conceptions of
citizenship are sufficient to explain cross-national differences in extreme right mobilizati-
on, First, it is clear that other aspects of political opportunity structure, such as the de-
gree of closure of the electoral system to challenging parties (cf. Great Britain) and the
loss of legitimacy of the traditional party system (cf. Austria, Italy) are important deter-
minants of the mobilization and success (or failure) of the extreme right in certain coun-
tries. Second, the success of the extreme right is often based not just on the mobilization
of xenophobic sentiments, but also on other themes such as regional separatism (cf. Bel-
gium, Italy) or neoliberal resistance against the welfare state (cf. Scandinavia). In what
follows, we will occasionally refer to the role played by nationally specific factors, such
as the system of direct democracy in Switzerland or the historic legacy of National
Socialism in Germany, in order to account for specific patterns of mobilization. We
think, however, that because questions of national identity are at the core of the pro-
gramm and discourse of the extreme right accross Western Europe, different conceptions
of citizenship and nationhood are likely to be an important source of systematic variation
beyond ideosyncratic factors relevant to specific countries.

2, Conceptions of citizenship and nationhood

As Tilly (1995: 8ff.) has observed, the word "citizenship" causes confusion, because it
can refer to a category of actors (distinguished by their shared privileged position vis-a-
vis some particular state), to a tie (a relationship between an actor and state agents), to a
role (including all of an actor's relations to others that depend on the actor's relation to a
particular state), or to an identity (the experience and public representation of a category,
tie or role). Following Marshall's (1950) classic treatment of citizenship as a set of rights,
he suggests that we confine the definition of citizenship to a certain kind of tie. Rather
than take up his detailed definition, we would like to stick to his general idea that citi-
zenship is best considered as a bundle of rights and obligations with respect to a given
state. The crucial issue with respect to citizenship defined in these terms is, of course, the
delimitation of the group which has access to this bundle of rights and obligations. A c -
 9

cording lo the classical model of the nation-state, the group of people who have access
to the complete bundle of rights and obligations linked to citizenship constitute the na-
tion corresponding to a given state. Access to citizenship may be formally defined in eit-
her ascriptive or achievement terms: citizenship may either be reserved to a primordial
group (ius sanguinis) or it may be achieved by all those who are born on the territory of
the state in question or who may otherwise be able to qualify for it (ius solis). Citizenship
of'the first type is defined in ethnic terms, and membership in an ethno-cultural com-
munity - the nation, is constitutive of the acquisition of citizenship. Citizenship of the se-
cond type is defined in political terms, it is to be obtained by all those who happen to be
born on the territory of a given state. In this case, citizenship is constitutive of mem-
bership in a given nation.
Among the bundle of obligations tied to citizenship, the cultural ones seem to be of
particular importance. In addition to the criterion of the formal bases of citizenship, we
propose, following Tilly (1995: 10), to introduce them as a second dimension characte-
rizing the relationship between citizenship and nationality. Citizenship may specify more
or less exclusive cultural obligations for those who wish to acquire it. In other words, a
given conception of citizenship may insist that all citizens conform to a single cultural
model (the exclusive case), while another conception of citizenship may allow for a varie-
ty of cullural patterns to be followed by its citizens (the inclusive case). Combining the
two dimensions relating citizenship and nationality, we arrive at a four-fold table (while
1
closely resembling Tilly's conceptualization, this table is not quite identical with it) :

1 Most of the literature on citizenship distinguishes three models, corresponding to the positions taken
by Germany, France and the Netherlands in this figure (for instance Baldwin-Edwards and Schain
1994, Smith and Blanc 1994). The combination of ethnically based formal citizenship with cultural
inclusiveness represented by the Swiss case may be empirically rare because of the specific character
of Switzerland as a multicultural nation by origin, but deserves to be theoretically taken into ac-
count.
 10

1
Relationship between citizenship and nationality

cultural obligations tied to citizenship

exclusive inclusive

innate Germany Switzerland

formal

basis of

citizenship

acquired France Netherlands

These four combinations each have distinct implications for policies with regard to immi-
grants, Germany represents the "ethnic-exclusive model". Since Herder and Fichte,
German nationalists have emphasized ethnic rather than "political" or "civic" criteria for
inclusion in the nation. Thus, in the German conception of nationhood, the nation is de-
fined in terms of a specific ethnic group (the "Volksgemeinschaft"), whose distinctive-
ness is expressed in a shared culture (Germany as a "Kulturnation"). In line with this
conception of the nation, the German constitution gives East Europeans with "ethnically
German" ("Volksdeutsche") ancestors almost automatic access to citizenship. By con-
trast, it is very difficult to obtain German citizenship for immigrants such as the Turkish
"Gastarbeiter" who do not belong to this "imagined community" (Anderson 1983). As a
consequence, Germany in the 1990s on the one hand has hundreds of thousands of child-
 11

ren of immigrants born, raised and educated in Germany who speak perfect German but
are still considered to be foreigners, while large numbers of Russian-speaking immigrants
born, raised and educated abroad are defined as ethnic Germans and enjoy full citizenship
2
rights . Thus, German immigration policy consisted of maintaining a strict legal and poli-
tical distinction between ethnic nationals and foreigners. German "Gastarbeiter" policy
amounts to integrating these immigrants through their participation in economic and so-
cial life alone, without giving them citizenship - the logical outcome of the German na-
tional project (Schnapper 1994: 135ff.).
Switzerland resembles the German case, since its citizenship is also very difficult to
obtain. Moreover, even more explicitly than is the case in Germany, the acquisition of ci-
tizenship is conditional upon assimilation to the "schweizerische Lebensgewohnheiten,
Sitten und Gebrauchen" (Kleger and D'Amato 1995: 266; Parini 1996: 113). However,
contrary to the German model, the Swiss state of 1848 was founded in a political vision
of the nation in the tradition of the French model, and united several, culturally distinct
peoples. Switzerland offers a plurality of cultural models to its citizens: the country is
composed of different linguistic communities which have learnt to live side by side within
the same nation. Thus, cultural heterogeneity is as such compatible with the Swiss' self-
understanding as a nation, and the presence of cultural minorities of foreign origin ap-
pears less as a threat to the integrity of the nation than is the case in Germany. From the
point of view of an immigrant seeking citizenship though, the Swiss situation is closer to
the German reality, given that naturalization in Switzerland is delegated to the local and
cantonal levels of the state. In actual fact, citizenship is attributed in a given linguistic
community and the immigrant is forced to adapt to the context of the subnational com-
munity where he ends up living. As a consequence, the rules and praxis of access to citi-
zenship may differ substantially among the cantons. Generally speaking, citizenship tends
to be more easily available in the French-speaking cantons than in the German ones,
which probably reflects German and French cultural influences, respectively (Kleger and
D'Amato 1995: 268).

2 The facilitation of the acquisition of German citizenship by these "Aussiedler" even goes as far as
allowing them to retain their original citizenship alongside the German one. Other immigrants,
however, can only get German citizenship if they give up their original nationality.
 12

France is quite distinct from these two countries. Its "Republican model" allows all sorts
of people to become French, but imposes a well-defined standard of Frenchness. The
French nation is a political community with the possibility of admitting newcomers to the
community, provided they adhere to the political rules and are willing to adopt the natio-
nal culture. France's traditional immigration policy is to turn immigrants or at least their
children, into French citizens (Hargreaves 1995). Since the French Revolution, the logic
of individual citizenship has been opposed to the political recognition of minorities,
whoever they may be. France has "assimilated" in this way successive waves of immi-
grants into a common political project: "The principles of 'French integration' continue to
be applied: the tradition of individual integration is so strongly entrenched that those
measures which have sought to recognise particular ethnicities have always failed"
(Schnapper 1994: 134).

To an important extent, the relatively easy access to, and in many cases even automa-
tic imposition of French citizenship must be seen as part of a deliberate attempt to pre-
vent the development or persistence of ethnic or cultural solidarities conflicting with the
unitary conception of the republican nation, i.e. naturalization is seen as a tool to ac-
complish cultural assimilation (Weil 1996; Kleger and D'Amato 1995). In the light of this
preoccupation with cultural homogeneity, the presence of culturally different minorities
in certain respects appears as more threatening to the ideal of the French nation than is
the case in Germany. The presence of ethnic minorities is to some extent tolerable within
the German context because the politics of citizenship ensure that these minorities remain
3
second-class citizens without political rights . The French ideal, on the contrary, is in-
compatible with ethnic and cultural difference tout court, precisely because minorities
have easy access to political rights. In the prewar period, this problem did not appear
very pronouncedly since assimilation policies were quite successful in integrating the Eu-
ropean migrant groups that were dominant at the time. However, with the arrival of large
numbers of migrants from Third World countries and especially from the Maghreb, who

3 As Birnbaum (1992) has noted, the historical strength of antisemitism in Germany may be partially
explained by the fact that the presence of the Jews, who were mostly German citizens and active
participants in German political life but were not seen as part of the German ethnic community,
conflicted with the ideal correspondence between ethnic Germanness and citizenship.
 13

are culturally more different and more resistant to assimilation, the contradictions betwe-
en the French republican ideal and the reality of increasing cultural heterogeneity have
become highly prominent in the debate on immigration.
The Netherlands, similar to the Anglo-Saxon nations and to Sweden, follows what
may be called a "multicultural model" of citizenship. Just like the French model, this
model readily offers citizenship to immigrants based on a definition of the nation as a
political community, but, contrary to the French model, it also willingly grants minority
cultural rights, and to some extent even actively stimulates cultural diversity. In the
Dutch case, this approach to cultural heterogeneity has a long tradition in the political
model of "pillarization" that was established as a way to deal with the country's religious
divisions and consisted of a combination of consensus politics at the elite level and cultu-
ral autonomy for each of the country's communities (Lijphart 1967). This model has
continued to shape Dutch politics even after the decline of the religious cleavages that
gave rise to it. With regard to immigrants, this has implied the active involvement of sta-
te-subsidized minority organizations in the policy-making process and the stimulation of
the perpetuation of minority cultures, among other things through state-sponsored
education in "own language and culture" within the school system. In line with this mo-
del, citizenship is not only formally easily accesible, but is not linked to any preconditions
or expectations with regard to cultural assimilation, either. Moreover, by the introduction
of the communal right to vote for all foreigners living at least five years in the country,
the Netherlands are at the forefront of extending political rights to non-citizens.
These differences among the four countries are confirmed by data on naturalizations.
Between 1988 and 1991, the number of naturalizations as a percentage of the foreign
population was 4.0% in the Netherlands, 3.3% in the U K , 2.7% in France, 0.7% in Swit-
zerland, and 0.5% in Germany. Within Europe, Sweden has the highest rate: 5.6% (Cinar
1994: 22). These differences do not seem to be related to the different composition of
the foreign population in these countries: while in 1991/92 5.1% of the Turks living in
the Netherlands obtained the Dutch nationality, in Germany this figure was as low as
0.2% (Cinar 1994: 10). As a result, the official figures on the size of the foreign popula-
tion in the four countries (17.4% in Swizerland, 7.9% in Germany, 6.4% in France and
 14

4.6% in the Netherlands in 1991; Eurostat 1994: 2-3 ) are partially an artifact produced
by the different politics of citizenship and do not accurately reflect the actual numbers of
people with foreign origins living in these countries. This is even more true if we take
into account that France and the Netherlands have taken up large numbers of immigrants
4
from former colonies, who were French or Dutch citizens by birth . At least for the four
countries studied here, therefore, the size of the population of foreign origin can largely
be ruled out as an explanation for differences in xenophobic mobilization.

3. Implications of the conceptions of citizenship

What are the implications of the different conceptions of citizenship and nationhood for
the mobilization of the extreme right? From a strictly material point of view, the implica-
tions of these different conceptions are not very significant, because, in the countries we
are dealing with here, the immigrants with a permanent resident status enjoy a bundle of
economic, social and cultural rights which is comparable to the corresponding rights en-
joyed by the immigrants who have become citizens of the respective countries. In his
comparison between the French and the German situation, Brubaker (1992: 181) also
points out that, for the immigrants in these two countries, the material interests at stake
are relatively minor: German citizenship "would add complete protection against expul-
sion, access to public sector employment, and eligibility for those few social services and
benefits that are limited to citizens. While not negligible, the marginal advantages confer-
red by citizenship over and above those conferred by the status of long-term foreign resi-
dents are of modest import. From the point of view of the immigrants concerned, citi-
5
zenship status as such does not decisively shape life chances" . This is a result of the ex-

4 Thus, taking first and second-generation migrants into account, the percentage of people with
foreign origins in the Netherlands including naturalized foreigners and people originating in former
colonies is about three times as high as the nominal number of foreigners (about 15% of the popula-
tion, computed on the basis of CBS 1996: 50-53).
5 For an evaluation of such cross-national differences as do exist, see Cinar, Hofinger and Waldrauch
1995. For our four countries, the differences correspond to those with regard to access to citizenship.
That is, the rights of non-citizen immigrants tend to be most restrictive where access to citizenship
is also restricted and vice versa.
 15

tension of the welfare state which, today, also covers the permanent foreign residents in
all the countries under consideration. Moreover, their formal access to the labor market
is hardly restricted at all. Informally, however, not only the permanent foreign residents,
but also the many immigrants who are or have become citizens of Western European
countries are confronted with a lot of stigmatization and rejection all over Europe. This
is expressed by the following assessment of a young immigrant citizen in France (cited by
Blatt 1995: 161): "You can have French citizenship, vote and have your diploma; to be
hired, it's your face that counts and the pronounciation of your name".
In spite of this convergence in the material situation of immigrants who have obtained
citizenship and foreign permanent residents, the conception of citizenship still makes a
difference. The deeply ingrained conception of citizenship molds the identity and the self-
understanding of society as a whole and of particular actors in society. It is linked to a
public representation which takes the form of nationalist narratives; it shapes and con-
strains the kind of claims that can (legitimately) be made and the kind of language in
which they can (legitimately) be articulated, and it is implemented in the immigration po-
licies of a given state. Following Brubaker (1992: 182), we argue that it is not enough to
consider citizenship in its "functional" context in terms of its contribution to the oppor-
tunities of immigrants or the exclusionary capacities of the state. The politics of citizens-
hip today first and foremost seem to be a politics of identity, and not a politics of inte-
rest. In fact, the uncoupling of rights and identities which has taken place in Western Eu-
rope seems to be at the very root of the present resurgence of nationalist identity politics:
"Rights that were once associated with belonging in a national community have become
increasingly abstract, and defined and legitimated at the transnational level. Identities, by
contrast, are still perceived as particularized and territorially bounded" (Soysal 1996: 18,
see also Hollifield 1992; 170-172). Accordingly, the central question with respect to citi-
zenship is no longer "who gets what?", but rather "who is what?".
In line with this idea, the mobilization of the extreme right may be interpreted as a res-
ponse to a crisis of national identity. Today's extreme right's mobilization is typically
viewed as a mobilization in defense of a threatened national identity and its nationalism is
said to be "un nationalisme de repli l'intrieur des frontires, que nul ne remet plus en
 16

cause; il n'est donc pas un nationalisme belliciste, mais ressemble un grand mouvement
d'auto-dfense de citoyens effrays par la plantarisation contemporaine, mouvement
auto-dfensif largi aux dimension d'une nation" (Taguieff 1992: 9). According to Genti-
le (1996: 75), the rise of the extreme right accross Europe is not accidental but responds
to "un besoin identitaire induit par la profonde crise des identits collectives que tra-
versent les pays du vieux continent".
The response given by the extreme right accross Western Europe to this crisis of
identity is the defense of, or the wish to return to an ethnic conception of nationhood,
which exludes all those not belonging to the supposed "ethnie" with its assumed
"common" cultural heritage. Thus, the German Republikaner fiercely object against any
move away from the purely ethnic conception of nationhood laid down in the German
constitution, while the Front National demands the suppression of all further naturalisati-
ons and a reform of the code de la nationalit along the lines of the ius sanguinis.
However, in forwarding these demands, the extreme right in the different countries has
to act within the context of the divergent dominant national discourses on nationhood
and citizenship outlined above. Thus, while in Germany and Switzerland the extreme
right's demands are basically no more than a radicalized version of the dominant concep-
tion of nationhood and citizenship, in France and even more so in the Netherlands the
realization of its claims would imply a radical redefinition of what it means to be French
or Dutch. Our hypothesis is that these divergent discursive opportunity structures will
have an impact both on the mobilization of the extreme right and on the amount of suc-
cess it is able to obtain with its ethnic-exclusivist claims. In order to investigate the me-
rits of this hypothesis, we shall now look more in detail at the extreme right and its rela-
tion to dominant discourse in each of the four countries.
 17

4. The extreme right and the politics of immigration

4.1 Germany

In contrast to France, which has a long history as a country of immigration, Germany has
traditionally been a country of emigration, especially to the United States, where in the
nineteenth century Germans constituted the single largest group of immigrants (Bade
1992, Thranhardt 1995). Since the Second World War, however, (West) Germany has
become one of the world's most important immigration countries. The first wave of im-
migration concerned the so-called "Vertriebenen", Germans that fled or were expelled
from Czechoslovakia, Poland, Russia and other East European countries. In the after-
math of the war, millions of these refugees came to Germany, especially to the Western
zones. They were joined over the course of the 1950s and until the construction of the
Berlin Wall in 1961 by hundreds of thousands of East Germans seeking a better life in
West Germany. These huge immigration waves occurred in the period of economic ex-
pansion known as the "Wirtschaftswunder" and could therefore be absorbed with relative
ease. Moreover, from an ideological point of view, these immigrants were highly
welcome. For one, the victimization of German refugees served to distract attention from
the burden of Germany's historic guilt and thus contributed to the reconstruction of a
legitimate sense of national identity. For another, within the context of the Cold War, the
stream of immigrants from Eastern European countries was a vehicle for deligitimizing
the Communist regimes and contributed to West Germany's self-image as the Western
world's bulwark against Communism and as the only legitimate German state.
There were thus strong geopolitical reasons and interests behind the fact that West
Germany retained the 1913 legislation on citizenship unaltered. Within the context of the
Cold War and a divided Germany, it was ideologically unthinkable to change the ethnic
conception of citizenship that defined East Germans and "ethnic Germans" from other
East European countries as part of the German nation represented by the West German
stale (Brubaker 1992: 168-171). For similar reasons, the comparatively very liberal
asylum legislation laid down in Article 16 of the German constitution enjoyed almost
univocal support. Until the 1970s, when most of the (not very numerous) asylum seekers
 18

came from communist countries, this part of immigration legislation likewise served
other, foreign policy, rather than immigration policy purposes. It was only after the
1960s, with the arrival of millions of "Gastarbeiter", above all from Turkey, that the eth-
nic model of citizenship began to serve other, exclusionary, purposes towards immi-
grants. Likewise, with the arrival of increasing numbers of refugees first from right-wing
regimes such as the Chile of Pinochet and then from Third World countries in the 1980s,
the liberal asylum legislation came under increasing pressure. For our present purposes, it
is important to note that the extreme right played no significant role, neither in the inclu-
sionary policies vis-a-vis immigrants from Eastern Europe nor in the subsequent instru-
mentalization of the ethnic model to exclude "Gastarbeiter" from citizenship.
Until the second half of the 1980s, the only challenge from the extreme right worth
Mentioning had been that of the "Nationaldemokratische Partei Deutschlands" (NPD) in
the second half of the 1960s. For this party, however, immigration politics was not an
important issue. Instead it mobilized on a combination of revisionism, law and order
strategies with respect to the 1960s student movement and opposition to West Ger-
many's first steps at normalization of relations with East Germany, Poland and the Soviet
Union. The founding of the "Republikaner" as a split-off from the Bavarian C S U in 1983
was not linked to dissatisfaction with official immigration politics either. Again, it was
the normalization of relations with Eastern Europe - this time in the form of a large loan
given by CSU-leader Strau to the GDR- and the threat to the extreme right's wish to
reestablish Germany in ist prewar borders this implied, that was decisive.
Over the course of the 1980s, however, immigration issues came to play an increa-
singly important role within the extreme right and contributed considerably to the electo-
ral successes of the Republikaner. This was certainly a result of the fact that despite the
political elites' ritual repetition of the formula "Germany is not an immigration country",
Germany had in actual fact become one of the most important immigration countries in
the world. Although it was clear that most of the immigrants and especially their children
would never return to their countries of origin, the ethnic model of citizenship precluded
any political integration of these permanent strangers. On the other hand, rhetoric and
election promises from the conservatives notwithstanding (see Thrnhardt 1993), the
 19

strong position of individual human rights within the German constitution, obligations to
international treaties as well as opposition from the Left and the Liberals have blocked
any substantive policy changes in the direction of reducing the rights or the number of
foreigners in Germany.
Asylum politics is an important exception to this, however. The early 1990s saw a
strong increase in the numbers of people, especially from the Eastern European coun-
tries, seeking asylum in Germany. This situation led to a polarized debate initiated by the
Christian Democrats who wanted to restrict the constitutional right to asylum. This deba-
te was accompanied by a wave of xenophobic violence, particularly directed at asylum
seekers, of an intensity that surpassed by far anything postwar Germany had seen so far.
This violence by the extreme right seems to have been remarkably successfull: restrictive
decisions in asylum politics including the 1992 decision to change Article 16 of the con-
stitution each time closely followed peaks of violence (see Koopmans 1996a, 1996b).
Thus, the only inclusive element in German immigration politics has also been abolis-
hed by now, while all attempts to integrate immigrants politically (by giving them voting
rights, liberalizing naturalization legislation, or allowing double nationality) have thus far
failed. This success from the point of view of the extreme right has been achieved
with remarkably little mobilization. In comparison with other Western European coun-
tries, the German extreme right is relatively weak: none of the postwar parties has ever
succeeded in passing the five percent hurdle required for entering the national parliament.
Moreover, it is highly fragmented among three main parties (Republikaner, NPD and
DVU) and several extraparliamentary groups. Partly, this weakness of the extreme right
is certainly a result of the relatively strong repression it faces in Germany. As a result of
Germany's historical legacy, there is a large body of repressive legislation affecting ex-
tremist organizations generally, and organizations spreading neonazi, racist and antise-
mitic propaganda in particular. Moreover, the Nazi past is an important factor deligiti-
mizing the extreme right in the eyes of large sections of the public.
Nevertheless, given the fact that the ideas for which the extreme right stands for are at
least as widespread in Germany as elsewhere (Hofrichter and Klein 1994), the most im-
portant reason for the relative weakness of the German extreme right seems to be pre-
 20

eruption: since the dominant ethnic-exclusivist discourse of citizenship and nationhood is

already close to the extreme right's ideal and the established conservative right already
6
defends and executes much of what the extreme right demands , there is often no need
for extreme right pressure. And when the extreme right does mobilize on xenophobic
claims, as in the case of the asylum issue, it tends to be relatively successful. Rapid suc-
cesses, in turn, contribute to demobilization, as is demonstrated by the fate of the extre-
me right parties, which during the peak of the asylum debate were able to enter several
stale parliaments, but, after asylum legislation had been changed, received less than 2%
of the vote in the federal elections of 1994.
However, with the collapse of East European communism and the pressure towards
harmonization of immigration legislation within the E U , the ethnic-exclusivist model is
likely to come under increasing pressure. The ethnic definition of citizenship can no lon-
ger be legitimated as part of an anticommunist strategy and with the official recognition
of the present borders by the German government it has lost much of its significance for
foreign policy (Weil 1996: 82-83). At the same time, even important sections within the
Christian Democratic party have come to the conclusion that something has to be done
to integrate the millions of foreigners that are there to stay. A n eventual shift in the di-
rection of a more inclusive politics of citizenship therefore seems inevitable. It is not un-
likely that under such new conditions the established conservatives will loose their ability
to integrate xenophobic demands and the extreme right will get expanded opportunities
for mobilization.

4.2 Switzerland

The discoursive opportunity structure of the extreme right in Switzerland is ambiguous.

Like in Germany, its discourse resonates well with the dominant conception of citizens-
hip and nationhood. However, it is rather at variance with other elements of the Swiss

6 This role is above all played by the Bavarian C S U and its representatives on the national level. It is
the official line of this party not to allow the development of any competitor to its right. The result
of this strategy is that representatives of the C S U often take positions with regard to immigration
politics that are hard to distinguish from those of the extreme right parties.
 21

political culture which stress cultural inclusiveness and tolerance for cultural heterogenei-
ty. Given the strength of the inclusive theme in Swiss political discourse, the extreme
right, more than in Germany, needs to mobilize in order to impose its point of view. The
direct-democratic opening of the Swiss political system facilitates this mobilization. In
fact, the direct-democratic procedures provide the extreme right with a particularly ef-
fective mobilizing tool, because they allow the extreme right to appeal directly to the
people on the specific issues which are most prominent in its programme. Given that the-
se issue-specific appeals can be couched in terms of the prevailing conceptions of citi-
zenship and nationhood, which become very salient at the time of a vote on an initiative
or a referendum launched by the extreme right, they are likely to have a high "narrative
fidelity" (Snow and Benford 1988), which, in turn, puts pressure on the political elites
and may force them to abandon parts of their traditional culturally inclusive strategies. It
is, therefore, no accident that the success chances of initiatives launched by the extreme
right are, in fact, much higher than the corresponding chances of the left (Papadopoulos
1991). By contrast, the extreme right's mobilization has met with greater difficulties in
electoral politics, where the restrictive conception of citizenship plays at best a subordi-
nate role and where the inclusive elements of political culture have traditionally been
much more important. Thus, during its first wave of mobilization in the early seventies
the extreme right obtained no more than 7.5% of the vote in federal elections, although it
was, at the time, able to mobilized almost half of the Swiss citizens in favor of its more
specific claims.
In the early postwar period, the discrepancy between the dominant restrictive concep-
tion of Swiss citizenship and the prevailing political and economic practices was particu-
larly striking. Swiss immigration policy was very liberal: the economy needed additional
hands and the government allowed them to be imported freely mainly from the European
South. In the fifties and sixties, the foreign population grew very rapidly. As a result of
this growth, immigration emerged as a major political issue in the early sixties (Schmitter
Heisler 1988). Pressures mounted as the extreme right submitted the necessary signatu-
res for a first of several initiatives against "overpopulation and swamping by foreig-
ncrs(t)berfremdung)". Under the pressure of mobilization from below, the government
 22

tried to stem the tide, but its (economic) liberalism prevented it at first from adopting
stringent measures. It was only in June 1970, shortly before the vote on the first initiative
against "berfremdung" that it fundamentally changed its position and adopted a very
restricted immigration policy. The initiative was rejected by a small margin of only 54%
of the voters. Without the change in the official immigration policy, the acceptation of
the initiative might have become possible (Dhima 1991: 52).
This first federal initiative of the extreme right called for the reduction of the foreign
resident population to one tenth of the Swiss population, which would have implied the
expulsion of 260'000 foreigners at the time. Later initiatives of the extreme right were
even more constraining. Thus, the third initiative of this type, submitted in 1972, asked
to reduce the foreign resident population to 500'000 persons, which implied at the time
that no less than 50'00 foreigners would have had to be expulsed within a period of
three years (Kriesi 1980: 220ss.). It is quite significant that the movement asked for not-
hing less than the expulsion of the foreigners. It is also quite significant that the official
policy did not take into consideration a more rapid naturalization procedure or other
measures for the integration of the foreign resident population in the Swiss society. In-
stead, its goal was simply to stabilize the number of foreigners. Just as the German po-
licy, it did not envisage the long-term consequences of the continued presence of a large
foreign population in Switzerland. In a sense, the extreme right drew nothing but the lo-
gical conclusion of the conception of Swiss citizenship.

We know quite a bit about the thinking of the partisans of these initiatives thanks to
an analysis of letters they sent to the editors of newspapers during the campaign before
the vote on the third initiative in 1974 (Windisch 1978). Note that this year marks the
end of the "30 glorious years" in Switzerland, which is to say that the menace exerted by
the foreigners was hardly an economic one at the time. Still most of the partisans of the
initiative of the Nationale Aktion (NA) felt that the foreigners were competitors and, on
lop of it, unfair competitors who benefited from important advantages. More important,
however, seems to have been the threat to the identity. In the discourse of the NA's ad-
herents, most of society's ills are in some way or another linked to overpopulation, which
has negative consequences for the environment, the scenic beauty of the country and the
 23

quality o' life (Windisch 1978: 80). Overpopulation leads to overindustrialization and is
thus the driving force behind environmental degradation. This degradation of the natural
environment, moroever, is paralelled by moral decay (ibid.: p. 88): prosperity has corro-
ded the true national values: labor, austerity, effort, honesty, unselfishness, devotion. The
theme of a small country, swamped by foreigners and under the threat of losing its soul is
omnipresent: "We are no longer masters in our own home" (p. 100). The adherents of
N A have the feeling of "drawing" in a mass of strangers, of being "submerged" and
"invaded" (p. 111). Over the course of the thirty glorious years, a life style has disappea-
red in Switzerland and the extreme right's adherents blame this on the "berfremdung".
With the departure of the foreigners, everything will be allright again. The struggle
against foreigners thus appears as the defense of a mythical past, or, in other words, of
an identity that no longer corresponds with reality As Barber (1974: 274) has put it, the
adherents of the extreme right "rendent les trangers responsables de la perte de leur
rustidle qui, en fait, leur a permis d'accder leur propre opulence".
Even it' the initiatives of the extreme right have not been accepted, the official policy,
under their pressure, has become very restrictive, changing thus both the discursive and
political opportunity structure for the mobilization of the extreme right. The official po-
licy now fell in line with the restrictive model of citizenship. As a consequence, the ex-
treme right has become insignificant in Switzerland until the arrival of a new type of im-
migrants, the political refugees, at the end of the eighties. In the meantime, as a conse-
quence of the official policy a growing share of the foreigners in Switzerland became
long-term residents who were increasingly integrated into Swiss economic and social life.
However, granting citizenship to these long-term foreign residents was still taboo. Since
the early nineties, attempts by the left in several Swiss cantons to extend political citi-
zenship rights to long-term foreign residents have all failed because of popular oppositi-
on (see Rennwald 1991). Moreover, an attempt by the federal government to introduce
facilitated naturalization procedures for second and third generation foreign residents in
Switzerland has been blocked by a referendum which was supported by a majority of the
voters in 1994. A n analysis of the reasons for this refusal indicates that the motivation
most often mentioned is that there are too many foreigners in Switzerland (Wernli et la.
 24

1994: 35). Those who generally mistrust the government and who are in favor of a de-
fense of Swiss traditions massively voted against the measure. This again suggests that
what is at stake is primarily a defense of a national identity.
More recently, the defense of the Swiss national identity and the issue of immigration
are also closely linked to the question of the Swiss adhesion to the European Union. The
opposition against the participation of Switzerland in the process of European integration
is focussing on the issue of immigration, on the one hand, and on the question of the
political institutions, on the other hand. The free circulation of people implied by E U -
membership reawakens the old fears of being "inundated" by waves of foreigners strea-
ming into Switzerland in search of paradise lost. In addition, the perspective of E U -
membership raises massive fears among the Swiss with respect to their political instituti-
ons. They are afraid that these institutions, especially Swiss neutrality, federalism and di-
rect democracy, will lose their significance once the country has joined the E U . These
institutions constitute the heart of the conception of Switzerland as a nation founded on a
shared political volition. In other words, EU-membership is particularly threatening for
Swiss national identity, because it puts into question both elements in the Swiss concep-
tion of citizenship its restrictive, ethnic conception, as well as its inclusive, political
conception of citizenship. Building on both conceptions of citizenship and nationhood,
the opposition to EU-membership is very strong. In december 1992, a majority of the
Swiss refused to join the European Economic Space. The extreme right, which is oppo-
sed to Swiss participation in the E U , gained an all time high of 9.3% of the vote in the
federal elections of 1995, with large regional variations (up to 17.1% in Aargau). What is
more, one of the four major bourgeois parties has decisively moved to the right and,
benefiting from its opposition to participation in the E U , has been the major winner of
these elections, becoming, for the first time, the largest party in the three largest Swiss-
German speaking cantons - Zurich, Bern and Aargau.
 25

4.3 France

Willi respect lo France, Birnbaum (1992: 430) has already formulated the hypothesis
"qu'en France, l'accs plus ais la nationalit facilitant l'intgration l'Etat-nation pro-
voquerait en retour une mobilisation nationaliste radicale au nom d'une identit culturelle
considre comme menace". One may, indeed, maintain that the civic rationalism of the
"Republican model" adhered to by French political and cultural elites may provoke a
particularly strong reaction. There has long been a counteridiom of nationhood in France,
originating in the conservative-organicist response to the French Revolution and decisi-
vely formed in response to the militantly secular Republicanism of the late nineteenth
century (Brubaker 1992:163). As Birnbaum (1992: 427) remarks, "par un curieux retour
des choses, le nationalisme la Herder se trouve son tour import en France par ceux
qui ne cachent pas leur propre refus dlibr d'un Etat de plus en plus loign du catho-
licisme". An ethnie conception of "la patrie" stood behind much of the attack on Dreyfus;
Maurras sought to define a true French nation free of Jews, Protestants, Freemasons and
other "foreign" influences. Le Pen and the Front national have revived this discourse ad-
apted to the special circumstances of the present.
The FN develops a myth, "qui consiste, la fois, penser la nation comme un grand
vivant ....'du mme sang'..., identifier la nation en tant que Gemeinschaft, et prsenter
la nation-communaut comme soumise des forces dsintgratrices mettant en cause sa
'survie'" (Taguieff 1992: 10). Thus, like that of the other West European extreme right
parties, the FN's discourse represents an ethnic-exclusivist conception of citizenship and
nationhood, at times including explicit antisemitic and racist elements. However, in its
propaganda directed towards the broader public, the F N usually adopts a more subtle
discourse that tries lo exploit the dominant Republican conception of French nationhood.
By focussing on the immigrants' alleged cultural unassimilability, the F N establishes a
strong link with mainstream political debates, and is able to claim, with some degree of
credibility, the status of a consequent defender of French national values. For this reason,
too, the FN's ideology distinguishes two categories of foreigners: those that are able to
assimilate, i.e. those of European origin, and those incapable or unwilling to assimilate,
stigmatising immigrants of extra-european origin. Integration in the national "body" is
 26

supposed to be possible only for the first category of aliens, on the condition that they
accept and are willing to assimilate to the structures and cultural values designated as
specifically French (Taguieff 1992:15s.).
Similar tactical use is made of the dominant discourse of assimilation in constructing
the FN's position regarding the politics of formal citizenship. While its programme calls
for a total abolition of the existing nationality code and the introduction of the ius san-
guinis, the FN's propaganda slogan "etre francais, cela se merite" suggests that the party
demands merely a consequent version of the French conception of citizenship: the merit
referred to, of course, is that of assimilation to French culture. These examples demon-
strate that the French conception of nationhood opens up opportunities for a culturalist
discourse of the extreme right. From this perspective, it is not surprising that the French
Nouvellc Droite (new right) was at the forefront of elaborating the modern, culturalist
version of intellectual racism embodied in the concept of "ethnopluralism".

Thus, in contrast to the situation in Germany, opposition to the liberal and universalist
elements of the French national project allows the extreme right to develop its own
identity and to maintain its distinction from the established parties. At the same time -
and here, as we will see, the French situation differs from the Dutch- other, culturally-
exclusivist elements of dominant discourse allow it to establish a legitimizing link betwe-
en its own claims and broadly-accepted notions of French national identity. In our view,
this possibility to employ parts of the dominant discourse as rhetorical weapons against
other parts of that same discourse, is one of the main reasons for the mobilization ca-
pacities of the French extreme right. A n additional and related factor is that these tensi-
ons within the French conception of nationhood have led to divisions within the political
elite from which the extreme right has been able to profit. If all the political parties seem
to be aware of the contradiction between, on the one hand, the French norm of cultural
unity and assimilation and, on the other hand, the reality of increasing cultural heteroge-
neity, the conclusions they have drawn from this differ strongly. The Socialists, especially
in the first half of the 1980s, through the notion of the "droit a la difference" tended to
go in the direction of solving the contradiction by moving towards the acceptance of
cultural diversity in the name of universalist liberal values. By. contrast, the Right, some-
 27

times joined by the Communists, tended to choose the opposite solution, namely that of a
stronger emphasis on assimilation and the elimination of cultural difference even if that
would imply a more restrictive application of human and citizenship rights to immigrants
(Husbands 1991).
As a result of this conducive discursive environment and the dividedness of the French
political elite, the FN has become a role model for extreme right parties accross the con-
tinent, being not only one of the strongest and most persistent, but certainly the most in-
tellectually and ideologically elaborated member of this party family. However, the same
political context that is responsible for the FN's strength also makes it a relatively unsuc-
cessful party when it comes to changing the substance of the politics of citizenship. Thus,
a first attempt to reform the nationality code by the 1986-88 Chirac government failed in
the face of massive resistance and the conservatives' defeat in the Presidential elections
of 1988. In 1993, a substantially less restrictive bill was finally adopted, which abolished
the automatic acquisition of citizenship at the age of 18 by immigrant children born in
France. Instead this group now has upon request a right to French citizenship. However,
because this right is absolute and the state is obliged to actively invite those concerned to
exercise it, the reform is more of symbolic than of practical relevance (Hargreaves 1995:
169-176). Thus, the reformed nationality code still remains firmly embedded in the Re-
publican tradition and still is a long way from the ethnic model favoured by the F N . The
same is true in the cultural field, where the extreme right may have been able to attract a
lot of attention, but has not been able to reach much substantive success. Thus the fa-
mous affair of the "foulard islamique" (islamic headscarf) in 1989 did bring the F N a lar-
ge victory in the by-elections in Dreux, but ended with the Conseil d'Etat's ruling that the
wearing of headscarfs by Muslim pupils in public schools did not contradict the Republi-
can principle of laicile, the strict separation of church and state (Hargreaves 1995: 126
127). So far, thus, the strong identification of French national identity with human rights
and an inclusive definition of citizenship has proved to be an insurmountable obstacle to
the FN's attempts to redefine the essence of "Frenchness" in ethnic terms.
 28

4.4 The Netherlands

Of the four countries analyzed here, the Netherlands have both the weakest and the least
influential extreme right. Apart from some obscure fringe groups, the extreme right did
not emerge on the Dutch political scene until 1982, when the Centrumpartij gained one
seat in the national parliament, with a score, however, of less than one percent of the
vole. In the 1986 elections, they lost their seat again, partly as a result of a split into two
parties, the Cenlrumdemocraten and the Centrumpartij '86. In the national elections of
1994, the extreme right got its best result in postwar elections so far, and gained three
seats in the national parliament. Still, with a bit more than 2% of the vote the strength of
the Dutch extreme right is not very impressive in comparative terms. This weakness of
the extreme right may at first sight surprise given the fact that the Dutch situation, with
its open access to citizenship and tolerance or even stimulation of multiculturalily devia-
tes strongly from the extreme right ideal and thus may be seen as particularly aggrieving
to those supporting an ethnic model of nationhood. The Dutch case thus demonstrates
once more that the strength of the extreme right is much less a function of the perceived
or actual threat of foreigners to the interests of the indigenous population, than of the
discursive opportunities the extreme right finds for the ethnic-exclusivist politics of na-
tional identity it promotes.

Much more than in the other three countries, the Dutch extreme right occupies an
ideological position that is in frontal opposition to the dominant discourse and institutio-
nal practice of citizenship and nationhood. Although, of course, there is a significant
portion of the Dutch population that holds xenophobic opinions, the extreme right has
not been able to exploit this potential to any significant extent. Within the Dutch political
debate, this is often related to the dilletantism, lack of qualified leadership and intellectual
poverty characterizing the two extreme right parties. However, from the theoretical per-
spective taken here, it is not surprising to find these characteristics in the Dutch extreme
right. The extreme right in the Netherlands faces enormous difficulties in linking ist eth-
nic-exclusivist claims to elements of dominant discourse that could provide it with cre-
dibility and legitimacy. For the same reason, there is no nationalist intellectual tradition
from which the extreme right could draw its own "organic intellectuals" . As a result,
 29

there is no equivalent of a "Nouvelle Droite" or "Neue Rechte" in the Netherlands and

the discourse of the Dutch extreme right amounts to little more than a reproduction of
common-sensical plattitudes and prejudices about foreigners.
In addition, the Dutch extreme right has been very unsuccessful in influencing the di-
rection of Dutch minority and immigration policies. On the contrary, the reaction of po-
litical elites to the emergence of the extreme right on the political scene in the 1980s has
been to extend rather than to restrict the rights of foreigners and to strengthen rather
than weaken their commitment to the multicultural model. Thus, foreigners have been
given the communal right to vote, new antidiscrimnation principles have been included in
the constitution, access to citizenship has been further facilitated and special programms
have been set up to increase the societal participation of immigrants, including positive
action program to improve their labour market chances.
These measures have, however, had relatively little success in preventing the deve-
lopment of an ethnic underclass with low levels of education and high unemployment.
Despite the Dutch politics of ethnic tolerance, the socio-economic situation of immi-
grants is in many respects worse than in countries with more exclusive policies
(Netherlands Scientific Council for Government Policy 1990). In the 1990s, this failure
has put increasing pressure on Dutch minority politics, which, in the eyes of its critics
may perpetuate processes of economic and social exclusion because "minorization" does
not stimulate immigrants to adapt to Dutch culture and thus to acquire the necessary pre-
requisites to succeed in the education system and on the labour market (Ter Wal, Verdun
and Westerbeek 1995: 238-241). This critique has been particularly advanced by the
conservative liberal party ( W D ) , who propose an alternative that is strongly influenced
by the French discussion and combines universalist principles with a politics of assimila-
tion of cultural difference (Husbands 1994: 196-197). This critique has had some influ-
ence on official minority policies, especially since 1994 when the W D became part of a
coalition government. One of the results was the introduction of
"inburgeringscontracten" (integration contracts) with immigrants, which among other
things oblige certain groups of immigrants with insufficient knowledge of Dutch to fol-
low a language course.
 30

Asylum policies, too, have recently become more restrictive, largely following the
model adopted in Germany and other E U countries. In the campaign for the 1994 electi-
ons, the W D made asylum politics one of its central themes, which may have contribu-
ted to the electoral gains made by this party. At the same time, however, the extreme
right was also strengthened in these elections. Thus, the, still cautious, shifts away from
the multicultural model seem to have opened up opportunities for the extreme right,
whose claims now resonate with the problematization by parts of the political elite of the
allleged unwillingness of foreigners to adapt.

5. Conclusion

These brief overviews of the situation in the four countries show that levels of mobiliza-
tion and success of the extreme right can indeed be meaningfully related to cross-national
differences in the dominant discourses and institutional practices governing the politics of
citizenship and national identity. As far as the substantive successes of the extreme right
are concerned, the relation seems to be fairly straightforward. In countries such as Ger-
many, where the extreme right's ethnic-exclusivist claims resonate with deeply-rooted
conceptions of nationhood, many of its demands can easily be taken up by parts of the
political elite, which serves to block any move towards extending the rights and status of
foreigners. On the contrary, where the gap between extreme right and dominant discour-
se is large, such as in the Netherlands, the extreme right has not only failed to get any of
its demands realized but has provoked extensions rather than restrictions of the rights of
immigrants and ethnic minorities. France is an intermediary case, where the extreme right
has been able to exert some policy influence because it could frame its demands in terms
of the dominant norm of a unitary, culturally homogenous nation. On the other hand, be-
cause of the French state's strong commitment to universalist values and individual hu-
man rights these policy shifts have remained mainly symbolic and hardly affect the rights
of the large majority of French immigrants. Switzerland should on the basis of its mixture
of ethnic citizenship and tolerance for cultural heterogeneity also be an intermediary case,
but in fact is quite comparable to Germany with regard to the amount of success booked
 31

by the extreme right. This deviation can be explained by the availability of direct de-
mocratic channels of decision-making, which allow the Swiss extreme right to directly
translate xenophobic potentials among the population into policy successes, bypassing
the political elite that has usually been in favor of a more inclusive politics of citizenship.
With respect to the levels of extreme right mobilization, we did not find a simple line-
ar relation with the degree of exclusiveness of the dominant conception of nationhood.
The two extreme poles among our four countries, Germany and the Netherlands, both
have a relatively weak extreme right, although for quite different reasons. In Germany,
the extreme right's mobilization problem is that it does not have a monopoly on ethnic-
exclusivist claims and is usually outflanked and preempted by the established conservati-
ves who are able to absorb much of the extreme right's electoral potential. In the
Netherlands the extreme right has such a monopoly, but lacks ideological and intellectual
bridges to the dominant discourse on nationhood and thus is confined to a marginal posi-
tion and lacks legitimacy and "seriousness" in the eyes of many voters. The extreme right
has been able to reach higher levels of mobilization in Switzerland and France where on
the one hand it can link its claims to widely shared notions of national identity, but on the
other hand appears clearly differentiated from and cannot be fully absorbed by the
established political parties because of its opposition to other elements of the dominant
politics of citizenship and immigration.
This result is in line with two propositions that have emerged from the wider literature
on the relation between political opportunities and the mobilization of social movements.
First, several studies (for instance, Eisinger 1973, Kitschelt 1986, Koopmans and
Duyvendak 1995) have shown that the relation between levels of success and mobilizati-
on is curvilinear. The highest levels of mobilization occur in political situations where
social movements confront a mixture of openness and closure, which on the one hand
ensures some successes that sustain mobilization but on the other hand prevents demobi-
lization because of too much (preemptive) success. In other words, mobilization is most
likely to be strong where it appears both opportune and necessary (Koopmans and Rucht
1995: 27). Second, as has been emphasized especially by Tarrow (1994: 88-89) the level
of social movement mobilization is related to the degree of unity or disunity among the
 32

elites regarding the themes addressed by the movement. Where social movements face a
unified elite, either opposed to, or supportive of their claims, challengers are not likely to
find much public resonance. A divided political elite, however, generally weakens the
position of the powerholders vis--vis challengers and opens up opportunities for the
latter to intervene as potentially decisive players in the political game. In the present stu-
dy such elite divisions have, of course, been most prominent in France and Switzerland,
the two countries with a hybrid dominant discourse that contains inclusive as well as
exclusive elements that have been differentially emphasized by different parts of the poli-
tical elite.
At first sight, these results seem to imply that from the point of view of combatting
the rise of the extreme right only the two extreme poles, the ethnic-exclusivist and the
multicultural model are viable options, since precisely the Swiss and French attempts to
combine integrative and exclusive elements have provoked the emergence of a strong
extreme right. Recent developments in the German and Dutch political debates on immi-
gration and ethnicity demonstrate, however, that these models are not in equilibrium eit-
her. In Germany, the political elite is becoming increasingly aware of the fact that in the
long run the ethnic model must be adapted because the exclusion of a growing propor-
tion of the population from political rights cannot be eternally maintained. The paradox,
however, is that in the short run a shift away from the ethnic definition of the nation may
provoke a defensive reaction leading to a strengthening of the extreme right. In fact, to
some extent, this is what has already happened in Switzerland in the course of the politi-
cal elite's attempt to open up the country towards the E U .
For very different reasons, the Dutch multicultural model has recently also come un-
der increasing pressure. Although the Dutch approach has been quite successful in
countering the extreme right, its politics of tolerance for cultural difference has also led
to a process of "minorization" or "ethnicization", which does not seem to have had posi-
tive effects on the level of socio-economic integration of the immigrant population. Thus,
like the German model, the multicultural model to some extent seems to have the unin-
tended consequence of perpetuating the social differentiation between immigrants and
 33

the "native" population. Of course, this is precisely the critique that has always been ad-
vanced against the multicultural model within the French immigration debate.
The Western European countries will all have to live with the continued presence of
large numbers of people with a different cultural and religious background that are not
likely to be assimilated as fully as earlier waves of intra-european migrants. Increased
cultural and ethnic heterogeneity, therefore, will inevitably have to be incorporated into a
new sense of national (and European) identity and in corresponding conceptions of citi-
zenship. So far, however, none of the four countries discussed here seems to have found
the optimal balance between tolerance for cultural difference, on the one hand, and the
need to provide immigrants with the necessary cultural tools - which imply a certain de-
gree of adaptation to the dominant culture - to escape from their situation of socio-
economic exclusion, on the other. This is one reason why accross Western Europe the
themes of immigration, ethnicity and citizenship are likely to remain an important focus
for political contention for some time to come.
 34

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