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Abstract
Even though the European Union (EU) and China are different types of political units, this article explains why they can be compared in a meaningful way as internal migration areas. National citizenship of an EU member state is compared to hukou status in China, as both constitute relevant affiliations to geopolitical units with decisive implications for social citizenship. The development of social citizenship with regard to these affiliations is described. A periodization of developments in relation to legal affiliation and social rights since the 1950s is suggested showing that there are converging trends between the EU and China. Nowadays, the EU and China are areas of virtually free movement. However, the EU is far ahead concerning the social rights of internal migrants, while China has only recently started putting efforts in this direction. As a result, internal migrants in the EU are much better protected against the loss of social rights when leaving their country of national citizenship than Chinese migrants who leave their hukou region. The issue of whether free movement and more accessible social rights for migrants represent a step on the road towards a full set of civil and political entitlements of citizenship is reflected in the conclusions.
Acknowledgements
This paper was produced in the frame of the project ‘Internal mobility and integration in the EU and China’ funded in the CO-REACH programme, promoting research cooperation between Europe and China (August 2009–January 2011). The authors would like to thank the German Federal Ministry of Education and Research for its support. Particular thanks go to Juwei Zhang, Albert Kraler and Karsten Giese for valuable comments and critical suggestions to an earlier version of this paper and to practitioners in Hamburg, Manchester and the Beijing district of Fengtai for offering their views on the implications of internal migration. Thanks for helpful comments also go to the journal's two anonymous reviewers.
Notes
1. Jutta Lietsch, Expo 2010 in Schanghai. Schaufenster in eine bessere Welt, taz 3 May 10.
3. Researchers argue that the hukou system constitutes an internal passport system in China (Bao et al. Citation2009, p. 4).
4. The Laws of Settlement with English parishes, the cantonal citizenship of Switzerland, the Heimatrecht of Germany and Austria and the Russian propiska linked social rights with localities. Early forms of federal citizenship in Germany, the USA and Switzerland in the eighteenth and nineteenth century can be compared to the European citizenship (Schönberger Citation2005).
5. For the use of local citizenship in the Chinese context, see Smart and Smart (Citation2001) and Smart and Lin (Citation2007).
6. Questions of civil or political citizenship are not analysed in this article.
7. During a discussion with government officials in a district of Beijing in May 2010 in the framework of a field trip in China, local officials were proud to point out that this practice did not persist in their district and that the situation generally improved.
8. Three regions are not considered for the paper: Hong Kong and Macau which constitute special administrative regions and Taiwan which is considered by China as its 23rd province.
9. Not until 1998 a child inherited the hukou from the mother. Since 1998, a general rule determines that a child may obtain the hukou from both parents.
10. There are four freedoms in the EU: the free movement of goods, capital, services and persons. The free movement of persons includes free movement rights, free establishment rights and free movement of workers. The freedom to provide cross-border services is distinguished from the freedom of establishment based on the temporary rather than permanent nature of the service.
11. Countries like Germany and later the UK entered with substantial and constantly growing numbers of migrant workers, from outside the EU (Turkey, the Indian and Caribbean subcontinent) but also from Southern European states like Spain, Greece and Portugal which later became EU member states.
12. In 2004, 10 new member states joined the EU: Czech Republic, Estonia, Hungary, Latvia, Lithuania, Poland, Slovakia, Slovenia, Cyprus and Malta (EU10). In 2007, Bulgaria and Romania (EU2) joined the EU.
13. A milestone of the establishment of freedom of movement was the abolishment of the border controls in the Schengen area in 1995. In 1999, the Schengen regimes had been transferred into the EU legal framework.
14. Before the 1980s, the social system in China was state-funded. Since the 1980s due to rapid privatization of state-owned enterprises and widespread commercialization, the level of social rights for urban population shrank. Major reforms of the social security system were initiated in the 1990s requiring contributions by companies, individuals and the state.