Introduction

Globalisation and increased migration to and within Europe have led to a growth in nationalisms and anti-equality, anti-diversity and anti-human-rights agendas inside and outside the EU (Banting and Kymlicka 2006; Rydgren 2012b; Wodak et al. 2012). Migration from non-Western countries has changed the social and political landscape in the Nordic countries. Norway, Sweden, Finland and Denmark have a democratic tradition of including peasants, workers and women in politics and society (Bergqvist et al. 1999). With their universal welfare states and strong egalitarian traditions, these countries are often included among the most equal societies in international rankings, particularly by class and gender.

Nordic welfare states have been successful in economic terms, and the basic components of extended welfare policies and redistribution are today supported by mainstream political projects. Since the 1970s, the countries have developed extended gender equality policies which are supported by the political left and the right. Social equality, democracy and gender equality have today become crucial elements in the Nordic sense of national belonging. Yet there are serious problems in relation to accommodating ethno-cultural and religious diversity and including immigrant minorities as equal citizens (Brochmann and Hagelund 2010).

Multicultural policies for accommodating ‘complex diversity’ point to social and political contexts in which diversity has become a multidimensional and increasingly fluid empirical phenomenon (Kraus 2011). The challenge that multiculturalism presents for social democracy – to renegotiate principles of economic redistribution with recognition of diversity – has entailed intense debates within the Nordic contexts.

The multicultural challenge to gender equality

Feminist scholarship has asked important questions about multiculturalism and gender equality and about the relation between women's rights and respect for cultural diversity. The objective of this chapter is to discuss the challenges from migration and multiculturalism in the context of the Nordic welfare states by looking at the tensions between gender equality and respect for diversity. The focus is on the gendered conflicts and tensions between gender and ethnicity in the Danish approach to citizenship.

The problem of multiculturalism and gender equality has only recently been addressed in the Nordic countries (Mørck, 2002; Siim, 2003; Andreassen, 2005). One inspiration is the debate sparkled by Susan Moller Okin's challenging article (1999), ‘Is Multiculturalism Bad for Women?’, in which Okin explored the tensions between group rights and women's rights and claimed that multiculturalism has been gender blind. The article raised an important debate about multiculturalism and feminism and about the relation between gender equality and respect for cultural diversity (Kymlicka, 1999; Parekh, 1999). Okin's article has been interpreted both as a useful feminist critique of multicultural approaches to group rights that often rate principles of racial equality above those of gender equality (Phillips, 2005) and as a simplistic and universalistic approach to citizenship and multiculturalism that fails to address the contextual nature of rights, family, religion and the public–private divide (Benhabib, 2002). Okin has recently addressed her critics and restated her position, emphasising that she is not against multiculturalism or group rights. What she proposes is that the majority has a special responsibility to women in minority groups whose oppression may be exacerbated by granting group rights and therefore the female members of patriarchal minority groups need to be consulted in debates about group rights (2005, pp 74–5).

Okin's article has raised an important debate about the role of culture and religion and about the voice of women in minority cultures. The article emphasises the negative role of religion and patriarchal oppression in minority cultures and it can be criticised for being insensitive to minority cultures. After 9/11 there has been a strong political trend to make culture and religion the cause of women's oppression and to treat minority women as passive victims of their culture (Siim, 2003). Against this background it is important to emphasise that issues related to gender equality, multiculturalism and women's rights are contextual and should be explored through transnational analysis.

Introduction

Since the 1990s, Western Europe has experienced a remarkable shift in political thinking about childcare. A profound politicisation of the relationship between the state and the family has generated renegotiations of the boundaries between public and private responsibilities in the care of young children. Parenting norms, parental responsibilities and relations are changing rapidly in many regions, while families and households are no longer expected to take full responsibility for the care of their children under school age. Policies aimed at reconciling paid work and childcare are accelerating these processes. With a special interest in the transformation of childcare – from private to shared collective responsibility and, in some welfare states, to a social right – this chapter takes as its starting point those policy shifts which are redefining access to various forms of childcare services and benefits as a social right of parents and children.

Within the European Union (EU) there is political agreement that childcare policies are essential in reducing gender inequalities and in changing the gendered nature of social and economic citizenship. This is most clearly evident in the Parental Leave Directive of 1996, the Recommendation on Childcare of 1992 and the targets set for the provision of childcare services at the European Council meeting in Barcelona in 2002. In fact, legislation and policy recommendations have redefined the young child's need for care as a responsibility of both the state and parents. Childcare policy reform has broadened the platform from which parents are entitled to make claims on the welfare state. The elaboration of public policies for the early childhood years is affecting the institutional arrangement between welfare states, families and labour markets, while childcare-related policies have added to the social and economic rights of mothers and fathers (Leira, 2002).

The transformation of childcare policies in Western Europe stands in stark contrast to the policy reforms since the early 1990s in those Central and Eastern European welfare states known in the 1970s and 1980s for their massive public investments in provisions for preschoolers (see Kamerman and Kahn, 1978, 1991; UNICEF, 1999; Heinen and Portet, 2004). Since the 1990s, the dramatic decline in the public provision of childcare services and benefits has meant a shrinking of the childcare-related social and economic rights of parents. The following analysis of national policy reforms covers Denmark, Finland, France, Germany, the Netherlands, Norway, Spain, Sweden and the UK.

Introduction

As context matters, a cross-national European study of the meanings of the concept of citizenship must, first of all, take the distinctive historical backgrounds into account. Understandings of citizenship have not only changed over the course of time, but its multifaceted, different meanings also reflect both varied political and social histories and legal traditions and cultures in the respective European countries. When, in this chapter, special attention is paid to legal traditions and cultures as characteristic of particular trajectories of development, this is not intended as a reduction to a legal discourse; on the contrary, it is an attempt to be concrete and extend our view of political ideas or conceptualisations to what is called ‘lived experience’. For the notion of ‘legal cultures’ comprises more than norms, doctrines or institutions of a legal system, it also includes attitudes towards the state and the practical experiences of those who were excluded from citizenship rights or became involved with the law. Since citizenship is not only a legal status but also a practice and lived experience (Lister, 2003), the awareness of the significance of legal cultures, therefore, may contribute to an understanding of ‘citizenship regimes’ as ‘historical constructions’ (Jenson and Phillips, 2001) and may explain specific barriers to equal citizenship or particular trajectories of inclusion respectively. These legacies, different historical roots and legal cultures, political struggles as well as particular institutional trajectories, still shape today's discourses and have an impact on citizenship theory and practice. Of special interest are the ‘overlapping vocabularies’ of the different discourses and debates with respect to female citizenship that impeded the possibility of gender equality (Landes, 1996). This means that the history of women's citizenship has deviated from the development usually depicted in the traditional citizenship literature.

In this chapter, however, the attempt at exploring the different historical and political contexts cannot be complete; it must be restricted to an exemplary or ideal type of argumentation. Since ideal types are always theoretical exaggerations, which in reality never exist in pure form, they will be illustrated by exemplary historical features. After introducing the terminology of the legal tradition and the models of the modern concept of citizenship, the second part of the chapter will discuss the delays and the impediments to women's citizenship in the different dimensions of political, civil and social citizenship rights.

Introduction

Globalisation, European integration and migration pose new challenges for understanding citizenship from a transnational perspective. Since the 1990s the increase in migrants and refugees has sparked new political debates about multiculturalism and multicultural policies across Europe, debates which have, increasingly after 9/11, been coloured by Islamophobia. These debates follow both similar and diverging paths in different European countries, all of which carry different legacies of colonialism, imperialism, and different histories of migration. In some, the debates about multiculturalism are new; in others, such as the UK, they revive and reshape debates of the 1960s following post-war immigration. Along with these differences, the heterogeneity of groups and the policies and lived experiences also constitute aspects of recent and past migration. With increasing immigration restrictions in Europe, the only way to gain legal access to enter many countries has been through family unification or as refugees or, to a lesser extent, as workers with designated and required skills. Since the early 1980s female labour migration has increased along with a growing stratification between different migrant groups, according to qualifications and skills (Kofman et al, 2005).

The overall objective of this chapter is to explore the meaning of these challenges of migration and multiculturalism for gendered citizenship. The focus is on the intersection of gender with (minority) ethnicity, in terms of the rights and claims of minority ethnic women, in those nine European countries which are the subject of this book, taking into account their differing citizenship, migration and gender regimes. Multiculturalism is an ambiguous term that refers to principles that either respect minority rights or defend special rights for minority groups. The debates point to how public policies deal with difference and diversity, as well as normative visions about diversity, and strategies for achieving these visions. Multiculturalism is also highly complex because, as Chapter Five shows, policies and public discourses often differ from the lived practices of citizens.

Migration and multiculturalism represent a double challenge for the classic framing of citizenship in that they force us to analyse the tension between equality and recognition of diversity and the relationship between national and transnational arenas. Citizenship is about the inclusion and exclusion of individuals and social groups in societies where struggles over rights have been closely linked to the nation state.

Introduction

In this chapter, we describe and analyse the range of actors involved in contemporary citizenship debates. These actors include left-wing and right-wing politicians, feminist movements, trade unions and social movements more generally. They may adhere to more dominant and powerful discourses on citizenship or struggle with alternative formulations, attacking mainstream or defending former interpretations. For all these reasons, it is not clear a priori whether citizenship is a liberating or a disciplinary concept; in fact, as stated in the Introduction, it can be both, depending on who is using the concept, in what context, and with reference to which kinds of vocabulary. From a gender perspective, such a contextualised analysis is especially important, since binaries such as public/private, dependence/independence, needs/rights, individual/community, may also be highly gendered, as well as context driven.

We focus here on those contextual issues concerning citizenship that have emerged within the European welfare states since the 1970s. We will start with asking why citizenship has become such a key concept. Then we will describe various contemporary vocabularies and feminist critiques of citizenship. In the next section, we examine some striking citizenship issues and debates in contemporary welfare states. Finally, we analyse the consequences of international developments for these vocabularies of citizenship, with a special focus on both European citizenship, and the framing of citizenship in former communist countries.

Social and political developments and the rise of the concept of citizenship

Within recent decades, citizenship has become an influential concept used in various spheres. Among academics it is used as a central concept to describe and explain developments within social and political transformation processes. In politics it is used to reformulate both the relations between citizens and the state, and relations among citizens. Within social movements and activist groups, it refers to questions of inequality, social cohesion and community life. In international organisations, such as the European Union (EU), the concept of citizenship appears to name and frame a shift in the position of the nation state and its citizens.

The main reason behind the popularity of the term ‘citizenship’ seems to be that so many contemporary issues and problems can be related to it. New questions have arisen as to the distribution of citizenship rights as a result of demographic developments, changing family and gender relations and welfare state reform.

Citizenship links the individual with the collective. This book too is the work of individual researchers who have worked collectively as an international team. The outcome is therefore not the more usual edited collection in which authors of individual chapters work with an editor. Rather it is the product of a collaborative process of iteration in which authors responsible for individual chapters have drawn on material provided by the whole team and members of the team have discussed and commented on each chapter. This process has helped to illuminate some of the challenges faced in researching citizenship in a cross-national context.

The introduction begins with an explanation of why it is necessary to understand citizenship in context. This is followed by a brief account of the meanings of citizenship and of feminist interpretations of them and, finally, an overview of the volume.

Citizenship in context

Citizenship can be understood both as an academic and political concept and as lived experience (Lister, 1997, 2003; Siim, 2000). Our analysis highlights three key elements of citizenship: rights and responsibilities, belonging and participation. The starting point for the volume and central theme running through it is that context matters. Although, as a concept, citizenship is typically constructed in abstract, universal terms, the universal nevertheless is interpreted and articulated in specific national social and political contexts, reflecting historical traditions and institutional and cultural complexes. Thus, for example, the British literature on citizenship has traditionally tended to focus on the relationship between individual citizens and the state, central to its liberal tradition; in contrast, the Scandinavian literature has been more likely than the British to emphasise the relations between citizens as a collectivity, reflecting the feelings of solidarity emanating from a long history of social democracy.

As lived experience, citizenship cannot be divorced from its context – temporal and national. Diverse aspects of gendered citizenship are salient at particular periods of time in different countries (see Chapters One and Two). Indeed, understandings of what it means to be a citizen, and the vocabularies used to capture these meanings, are likely to differ to some extent between European countries, as discussed in Chapter One. Moreover, within countries people may experience citizenship differently depending on factors such as age, class, ethnicity, religion, gender, sexuality and (dis)ability. These factors interact to weave the texture of lived citizenship for individual citizens (see also the Conclusion).

Introduction

The previous chapters have examined changes in the perception and application of citizenship rights in relation to childcare provision and to migration and asylum. This chapter looks at what Chapter Four called the ‘transnational redistribution of care work’ – the ways migration and childcare intersect in the case of the private employment of migrant women as domestic and childcare workers in European households. This phenomenon has been referred to as ‘the global care chain’ (Ehrenreich and Hochschild, 2003) where women from poorer regions of the world migrate to care for the children and households of employed women in the West in order to support their own children who they leave in the care of female relatives in their countries of origin. Research on the care chain in Europe has exposed the highly oppressive nature of such work and the ways in which migration rules and regimes render women vulnerable, through lack of citizenship status, to work in the underpaid and undervalued grey economy of household labour (Phizacklea, 1998; Anderson, 2000; Kofman et al, 2000; Lutz, 2002; Cox, 2006). The chapter draws on empirical qualitative research in the UK, Spain and Sweden with both employers of migrant domestic/care workers and migrant women who carry out such work. While it reinforces some of the findings of research on domestic service, it seeks to focus more on the demand for childcare services and contextualise this in terms of wider social and policy changes. The chapter starts by looking at this context and outlines the many different and complexly connected dimensions of citizenship it invokes.

Domestic work is both a new and an old phenomenon. While such work had been commonplace in bourgeois homes in Europe up until the 1960s, it fell away with the mass use of domestic technology, with the increase of alternative work in the industrial and service sectors, as well as, in the Nordic social democratic countries, a repudiation on egalitarian grounds of the very idea of employing others to provide ‘service’. By the 1990s it became evident in Western and Southern Europe that the demand for such work was on the increase again (for Britain, see Gregson and Lowe, 1994), and in the major cities it was in part migrant women from the poorer regions of the world who were meeting this demand (Anderson, 1997).