We would like to thank Delphine Perrin and Constance De Gourcy for proofreading this editorial and for their valuable suggestions. This topical collection follows the workshop organized by Karine Lamarche and Fanny Jedlicki in Nantes in October 2019, with the financial support of the CPER DI2L2S.
1As a result of the increasing mobility of individuals on a global scale and the changes that have affected modern nation-states, the number of people holding at least two citizenships is increasing, to the point where multiple citizenships is becoming a “new global norm” (Harpaz, 2016: 5). This phenomenon has its roots in the migratory heritage of societies and can be explained by a number of factors, including the growing importance of jus soli (right of the soil), greater gender equality that allows women to retain their nationality after marrying a foreign man and pass it on to their children, but also the efforts of emigration countries to maintain ties with their emigrants and diasporas (Dufoix et al., 2010; Amit, 2014: 396-397; Weil, 2011). The proliferation of dual citizenship thus reflects a change in relations between states, as well as between each state and its citizens.
2Although numerous studies have been carried out on the ways in which states perceive plurinationality, try to combat it, or, on the contrary, adapt to it, research on the meanings given to it by the first persons concerned and the concrete uses they make of it remains patchy. In France, where nine out of ten people with dual citizenship are immigrants (INED/INSEE, 2008), the phenomenon is studied almost exclusively through the lens of immigration and naturalization. In the rest of Europe and the world, however, other means of acquiring citizenship have expanded rapidly over the past twenty years. These include ancestry-based citizenship, kin citizenship, birth tourism, or citizenship by investment, which is investing large sums of money in a country’s economy in exchange for citizenship. In contrast to the citizenship that immigrants acquire in their host country, usually after lengthy and uncertain procedures, these different ways of gaining access to an additional citizenship usually take place at a distance from the country of origin and are rarely accompanied by prolonged residence there. These modes of acquisition have received far less attention than naturalization in both the Anglophone and Francophone literature (Vink and Bauböck, 2013; Sredanovic and Stadlmair, 2018). Nevertheless, they are significant for the ways in which states conceive of their national community and sovereignty, on the one hand, and for the representations to which the nation, national belonging, and the rights associated with citizenship are subjected, on the other.
3By bringing together works on contexts characterized by different modes of access to citizenship and degrees of tolerance towards pluri-nationality, this topical collection aims to broaden the focus usually adopted in the popular discourse, which automatically associates nationality with a sense of belonging, in order to free it from the emotional and normative rut in which it is too often trapped. As the articles in this topical collection point out, the acquisition of an additional citizenship can be motivated by many factors other than identification with one’s country of origin, starting with the desire to increase one’s own and one’s children’s international mobility capital in a world where not all passports offer the same freedom of movement-far from it. Mobility is, in fact, the common thread that links the various case studies presented here: past family mobility in the case of descendants of migrants recovering the nationality of their ancestors; present mobility in the case of candidates for a second citizenship; future mobility in the case of those who take these steps with their future and that of their children in mind. Finally, although primarily geographical, the mobilities discussed here can also be social: the steps taken to obtain the citizenship of a country other than one’s own on the basis of one’s national or ethnic origin are often motivated by the hope of improving one’s professional opportunities and/or the desire to distinguish oneself socially from the rest of one’s fellow citizens.
4In the articles selected for this topical collection, we have deliberately chosen to focus on empirical cases — and thus on the contemporary period — dealing with citizenship acquired by means other than naturalization in the context of immigration. Different types of procedures are analyzed: the granting of nationality through descent, through financial investment, or as part of a policy of reparation for wrongs committed against a section of the population. The contributions allow us to observe the social dynamics linked to the acquisition of an additional citizenship on several continents (Europe, Asia, North America, and Latin America), thus revealing the deep intertwining of migratory histories and practices and the representations of nationality — and thus of the nation — in force in different areas of mobility. Finally, the plurality of case studies allows us to approach the question of multiple citizenships from different angles: that of the candidates for acquisition, that of the legal intermediaries who facilitate the processing of their applications, and that of the provider state. By shedding light on the discrepancy that can exist between the rationale underlying state policies on nationality and the rationale that drives a growing number of individuals to acquire an additional citizenship, this topical collection aims to take a fresh look at the meanings and representations associated with this phenomenon, as well as the different uses that can be made of multiple citizenship.
5The terms nationality and citizenship, while referring to realities that are familiar to everyone, have a somewhat elusive dimension. They can be used almost interchangeably, as in English, or they can have different meanings, as in French. They can also have different meanings depending on the time and context in which they are used. A few terminological and linguistic clarifications are therefore in order here, especially since this is a bilingual topical collection. In French, the term citoyenneté refers both to a legal dimension (to be a citizen of a state is to have a legal link with it) — in which case it is synonymous with nationalité — and to a participatory dimension (to be a citizen is to take part in the life of the city, for example by voting). Some works on citizenship focus on this second dimension (Duchesne, 1997; Mariot, 2011; Neveu, 2013).
6The English-language literature attributes up to four dimensions to the concept of citizenship (understood as encompassing the meanings of both citizenship and nationality): status, set of rights, sense of belonging, and political participation (Marshall, 1950; Joppke, 2007; Shachar et al., 2017). Thus, the concept of citizenship encompasses the two dimensions associated with the French word citoyenneté (legal and participatory), but also an affective dimension related to the individual’s relationship with the nation. In French, on the other hand, to refer to the bond or sense of belonging that binds an individual to an imagined national community, in the sense of Anderson (1983), it is the notion of appartenance nationale [national belonging: trans.]. In this topical collection we will use both terms interchangeably.
7Until relatively recently, the relationship between an individual and the state of which he or she was a national had to be exclusive. The possession of more than one citizenship was seen as a threat to the interstate order, especially in view of the risk of multiple loyalties in times of war, and as an obstacle to the integration of immigrant populations, which threatened the social cohesion of the host countries.
8The great transatlantic migration that began at the end of the 19th century made these issues particularly acute: within a few decades, some 38 million migrants, mostly from Europe, made their way to the Americas. While the majority settled in the United States and Canada, Argentina, Brazil, and, to a lesser extent, other Latin American countries received extremely large numbers of Italians, Spaniards, Poles, Germans, and others. The nationality laws of modern European states emerged in the wake of these population movements. Based on the right of blood, they attribute citizenship to an individual according to his or her ancestry. The aim was and is to strengthen the ties between emigrants and their homeland (Green and Weil, 2006), thus reaffirming the sovereignty of emigration states over their emigrants (Cook-Martin, 2013). For their part, and at the same time, the American states, built by settlers and immigrants, adopted legislation based on the right of the soil, allowing the massive and quasi-automatic naturalization of newcomers (Rosoli, 1986; Choate, 2008). A real competition developed between the countries of origin and the host countries of European emigrants, at a time when the borders of their territories and those of their national communities were being consolidated. Dual citizenship, as a model of political belonging and membership, thus transcends the domestic perimeter and unfolds in an international arena characterized by mobile populations and issues of sovereignty between states (Faist, 2007b). This explains why, although formally opposed to dual citizenship, several emigration countries in the twentieth century tolerated it de facto, as Italy and the United Kingdom (Joppke, 2003; Faist, 2007b).
9The preamble to the Hague Convention of 12 April 1930 on “Conflicts of Nationality Laws” illustrates the hostility aroused by multiple citizenship and the desire to limit its number. It states: “Every individual should have one nationality and one nationality only” (paragraph 3). In 1963, the Council of Europe reaffirmed this hostility in a convention aimed at reducing cases of multiple citizenship by depriving any citizen of a signatory country who acquired a second nationality of his or her original nationality. The situation began to evolve in the 1970s and changed radically in the 1990s as family immigration to Europe increased. In the wake of a general movement in favor of individual rights and gender equality in the second half of the twentieth century, more and more countries abolished the rule that required women married to foreigners to lose their nationality of birth. In addition, several European countries began to allow children of bi-national marriages to retain the citizenship of both parents, and children of foreign parents to acquire the nationality of the country of their birth (right of soil). During this period, there has been a significant increase in the acceptance of dual citizenship in Europe and the Americas (Faist, 2007a; Sejersen, 2008), as well as in the Maghreb and sub-Saharan Africa (Perrin, 2017), up to the current situation where more than half of the countries in the world allow their citizens to hold another nationality, some unconditionally, others with restrictions (Faist, 2007a; Blatter et al., 2009). However, some countries, such as Haiti, Japan and China, still do not. These variations reflect the different conceptions of nationhood that prevail in each country.
10The history of migration in France is strongly influenced by the country’s colonial past. Much of the research on pluri-nationality therefore logically focuses on the experiences of bi-nationals from formerly colonized countries such as Algeria or Morocco, the reasons that led them to acquire French citizenship, the uses they make of it, and the representations they have of their legal status as bi-nationals (Chattou and Belbah, 2002; Ribert, 2006; Labat, 2010). Following Sayad’s work (1994 and 2014), a number of studies have also focused on naturalization as a procedure and a moment that reveals how the national community constructs its boundaries between “us” and “others” (Spire, 2005; Fassin and Mazouz, 2007; Hajjat, 2012; Mazouz, 2017). Finally, against the backdrop of tensions over pluri-nationality, the book edited by Perrin (2017) set out to explore this phenomenon by looking at both the public policies that frame it and the political arguments that target it, as well as the practices and experiences of those primarily affected — bi-nationals.
11While the migratory experience is at the center of these various studies of France and the Maghreb, in the last decade or so a wealth of English-language literature has begun to dissociate multiple citizenships and migration by focusing on nationalities described as “external” or “extraterritorial” (offshore citizenships), i.e., those acquired at a distance from the provider state. Four types of citizenship emerge from these studies: citizenship “by descent” or “inherited”, acquired by people whose ancestors came from countries with imprescriptible blood laws, such as Italy, Poland or Germany (Harpaz, 2019; Blanchard, 2020; Jedlicki et al., 2020); citizenships granted on the basis of belonging to an ethno-national minority: Romanians from Moldova, Hungarians from Serbia, or Germans from Russia (Brubaker, 1998; Pogonyi et al., 2010; Knott, 2022); citizenships resulting from “birth tourism”, i.e., having one’s child born in a country with unconditional birthright citizenship, such as Canada or the United States (Grant, 2015; Altan-Olcay and Balta, 2016, 2020; Harpaz, 2019); and those acquired in exchange for financial investments or substantial monetary “gifts” (Džankic, 2019). The first two modalities of access to an additional citizenship have been considered by some researchers as provisions for selecting migration, privileging some countries of origin over others (Joppke, 2005; Dumbrava, 2015; Pogonyi, 2022). Joppke (2018) notes that while states have always had a strategic perception of citizenship, especially in international relations, the strategic use of citizenship by individuals, who take advantage of opportunities that states have often inadvertently created for them, is peculiar to the contemporary era. According to the author, the instrumentalization of citizenship can be explained by three main factors: the rise of “citizenship by investment”, the expansion of external citizenship regimes, and the fact that European Union (EU) citizenship lacks an identity dimension. The Europeanization of citizenship adds another dimension to the concept of instrumental citizenship. Indeed, European citizenship is seen by some researchers as a typical example of “citizenship light” (Joppke, 2010): it brings rights — especially the right to free movement within the Schengen area (Bauböck, 2019) — but no additional obligations. The importance of the Europeanization of citizenship is all the more visible in the aftermath of Brexit. Indeed, recent studies show how some Britons are trying to reclaim the citizenship of an EU member state that their ancestors had (Godin and Sigona, 2022; Sredanovic, 2022).
12From the point of view of the actors involved, it is not insignificant that citizenship is often perceived as a somewhat abstract step towards obtaining an object whose materiality is in fact very real: a passport. For example, it’s not so much Italian, Hungarian, or Polish nationality, but rather the European passport that motivates Argentinians, Israelis, or Serbians to take the steps to obtain citizenship in one of these countries. This second passport can have a wide range of meanings and potential uses: as a resource for greater international mobility, as a sort of an insurance policy guaranteeing the ability to leave one’s country quickly in the event of war or regime change, as an instrument of social distinction in immigrant settler societies where European origin continues to be valued more highly than autochthony, as an element of family heritage passed down from generation to generation, as a means of increasing one’s professional, educational, or financial investment opportunities, and so on. This explains why recourse to an additional citizenship, whether inherited or acquired, is very rare in North America or Western Europe: while millions of people could apply for Italian or Polish citizenship in the United States or France, this phenomenon remains anecdotal. Indeed, if you already have American or European citizenship, there’s little point in taking steps to obtain an additional nationality based on distant family origins. In Argentina, Israel and Chile, on the other hand — countries that have received large contingents of Polish and Italian migrants — these applications are a real social phenomenon, once again demonstrating the utilitarian rather than identity-related dimension of this practice.
13The contributions to this topical collection all deal with the cross-cutting issue of mobility. They approach it in different ways, depending not only on the perspective of analysis chosen, but also on the specificities of the context of investigation. The articles by Daniela Trucco, Lorenzo Cañás Bottos and Tanja Plasil refer to older emigrations dating back to the 19th and 20th centuries, linking Italy and Lebanon with Argentina, respectively. Other articles deal with the consequences of intra-European emigration in the second half of the 20th century: Évelyne Ribert’s article looks at how the descendants of Spanish Republicans living in France seized the opportunity to recover their ancestors’ citizenship. Garance Clément’s article looks at the French-Belgian and French-Swiss binational citizenship acquired by cross-border commuters. A more recent form of intra-European migration is the focus of Djordje Sredanovic’s contribution. He analyzes the tactics used by British citizens, as well as EU citizens living in the UK, to respond to the loss of rights associated with British citizenship as a result of the UK’s exit from the EU. Finally, three articles deal with emigration from Asian countries. Paul May, in his article on Chinese using Canada’s citizenship-by-investment program, also looks at more recent migration, partly linked to global warming and pollution issues. Sanzhuan Guo and Tim McFarland look at Chinese migration from a historical perspective, analyzing how Chinese people in Indonesia reacted in the 1950s to a change in Chinese nationality law that forced them to choose a single citizenship. Eline Delmarcelle’s article makes an original contribution to the binational phenomenon by analyzing the case of mostly Western migrants to Japan who seek naturalization in that country. They are confronted with a Japanese law that imposes the principle of a single citizenship. Through these articles, pluri-nationality seems to be generated by different types of mobility (voluntary, forced, climatic, professional, family, ancestral, etc.), both present and past.
14The articles in this topical collection are organized around three cross-cutting themes. The first deals with the family transmissions and affiliations that emerge when we analyze the acquisition of an additional ancestral citizenship. Attachment to family origins, the sense of belonging to a lineage and, consequently, to a nationality, are explored in the case of Argentines of Lebanese origin (articles by Lorenzo Cañás Bottos and Tanja Plasil) and in that of Britons of Italian and Irish origin (article by Djordje Sredanovic), but also in the case of the descendants of Republicans “expelled” from Spain (article by Évelyne Ribert) and of Franco-Belgian and Franco-Swiss cross-border commuters (article by Garance Clément). These contributions illustrate the extent to which recourse to nationality through jus sanguinis is both a family and an individual affair. They also show that taking steps to acquire the citizenship of one’s ancestors sometimes leads to the reappropriation of a forgotten and painful memory, and thus to the redefinition of one’s place within a larger family history that spans several countries and continents. In doing so, they can help to consolidate intergenerational ties and reconnect with a country of origin with a troubled history, as in the case of the descendants of Spanish Republicans. The articles show the extent to which kinship relationships influence the decision to take up nationality, and analyze the relationship between kinship, citizenship, and a sense of national belonging. They also show that dual citizens understand their relationship to the two countries of which they are citizens as a function of their family history on the one hand and their individual trajectory on the other, but also as a function of the course of history.
15The second cross-cutting theme of this thematic dossier concerns the relationship between individuals and states, as reflected in nationality policies and their implementation. While states are by definition sedentary and territorialized, their citizens are increasingly mobile. In order to maintain their sovereignty over the latter, states adopt strategies that sometimes involve the granting of extraterritorial citizenship. By defining the legal and formal bases on which citizenship can be acquired, each state defines the limits of its authority. Lorenzo Cañás Bottos and Tanja Plasil, for example, tackle the nationality legislation adopted by Argentina to absorb its new immigrants and turn them into Argentines, and, at the same time, the efforts of the Maronite Church to encourage Argentines of Lebanese origin to recover the nationality of their ancestors in order to support Lebanon’s demographic policy. Daniela Trucco, for her part, studies nationality law “in deed” and “in practice”, focusing on the non-governmental intermediaries that implement it in the case of extraterritorial acquisition of Italian citizenship by descent. She shows that this means of entry into the Italian national and political community is the product of interactions and sometimes confrontations between actors who do not necessarily share the same vision of the “Italian nation”. Eline Delmarcelle, for her part, shows the pressure exerted by officials of the Japanese Ministry of Justice on foreigners applying for naturalization to renounce their nationality of birth once they have acquired Japanese citizenship. In Japan, mono-national allegiance is considered one of the essential criteria for defining a “good citizen”, along with respect for the law. Finally, Évelyne Ribert shows that the law granting Spanish nationality to the descendants of exiled Republicans is a response to the need to make amends for the damage suffered and thus to the demand for recognition of their family history.
16Finally, the third and last cross-cutting theme of this topical collection concerns the resources and capital expended for, but also provided by, the acquisition of an additional nationality. Paul May’s article on Chinese nationals who acquire Canadian citizenship by investing substantial sums in the local economy is exemplary in this regard. Following in the footsteps of works that understand nationality as a tool of social stratification and a “strategy of resource accumulation” (Harpaz, 2016: 2), he shows that access to Canadian citizenship through investment generally stems from the desire to give one’s children the best chances of success in a globalized capitalist world. But this is not the whole story. Djordje Sredanovic, for example, addresses the issue of the “EU bonus”, understood as the mobility capital associated with European citizenship, and the significance it will have for British citizens who lose it as a result of Brexit. In his study of Britons seeking to acquire the Irish or Italian nationality of their ancestors after the UK’s exit from the EU, he analyzes the different capitals (familial, cultural, economic) mobilized to succeed in this endeavor. Finally, examining situations in which people acquire an additional nationality which value is virtually “equal” to the one they already possess, Garance Clément shows that becoming bi-national does not simply increase one’s international capital, as numerous studies have shown, but constitutes a “localized resource mobilized in addition to other resources to support residential, educational, or fiscal strategies”. The question of symbolic capital, often raised in connection with the acquisition of citizenships that are considered stronger or more prestigious on the international scene, is thus re-examined here through the lens of autochthony: for these cross-border commuters, the acquisition of Belgian or Swiss citizenship is a way of affirming their place in local and national spaces and of distinguishing themselves socially and racially from the other foreigners who live or work there.
17The aim of this topical collection is to introduce into the French-speaking academic field work on multiple citizenships that highlights the diversity of the phenomenon and decouples it from naturalization alone. This topical collection also aims to contribute to the rich debate on multiple citizenships in three ways: first, by bringing together contributions on Western countries where dual citizenship is accepted and on Asian countries, such as China and Japan, where it is not. While research on dual citizenship has so far focused mainly on Europe and the Americas (Harpaz and Mateos, 2019), this comparative perspective allows us to examine the representations and uses of multiple citizenships in contexts marked by very different histories (migratory, but not exclusively so) and conceptions of the nation. Until the 2000s, most Asian states did not accept dual citizenship. During the 2000s, the nationality laws of several Asian countries evolved toward greater tolerance of dual citizenship, but China, Japan, and India continue to prohibit it. We should also remember that the notions of nationality and nation have their origins in a Western experience, that of the nation-state, which was established at the cost of many clashes and upheavals from the mid-nineteenth century to the end of the Second World War. In other words, it is an experience and a concept that has been exported and adapted to other continents and societies with different forms of political organization (Bénéï, 2007). In summary, this dossier shows the existence of a radical difference between the acceptance of dual citizenship in European and American states and its rejection in the Eastern states studied here (Japan, China). It shows that in countries where dual citizenship is accepted, the question of emotional attachment to nationality is of little importance, while the question of instrumental use of citizenship is central; conversely, in countries where dual citizenship is not tolerated, the nationality one loses or acquires is inevitably charged with a strong emotional meaning.
18Second, this topical collection takes a fresh look at the concept of instrumental citizenship, proposing to make the meaning generally ascribed to it more complex. Far from adopting an exclusively legal interpretation of instrumentality, which would amount to access to administrative and legal rights, such as the right to free movement or the right to move to a country offering better living conditions, this topical collection recognizes that an additional ancestral nationality is also symbolic capital to be “spent” in the country of birth, as in the case of Argentines of Italian origin (Daniela Trucco). However, this topical collection aims to take the reflection on the social value of instrumentality a step further: the acquisition of an additional nationality can be a means of achieving greater social inclusion in the country of residence. This is demonstrated by Eline Delmarcelle’s article on candidates for Japanese citizenship and Garance Clément’s article on French-Belgian and French-Swiss dual citizenship. Although the academic literature generally contrasts instrumentality and identity, utilitarianism and symbolic value, we believe that instrumentality can be understood in a more complex way if we recognize its symbolic and social value. From this perspective, instrumentality would then be specific to any means of acquiring an additional nationality, whether through naturalization or the acquisition of an ancestral or ethnic citizenship by blood.
19Finally, by bringing together contributions that deal with different ways of gaining access to an additional citizenship and contexts characterized by different nationality laws, this topical collection provides an insight into the variability of conceptions of the nation at work. This concept has been widely debated in the history of ideas, especially since the 18th century, when two ideal constructs clashed: first, that of a nation characterized by shared objective characteristics (language, culture, history, origins, etc.); second, that of a nation that would be the result of an act of self-definition, an “everyday plebiscite”, to quote Ernest Renan’s famous words. These two conceptions of the nation give rise to concepts of nationality based on different principles (in the first case, the right of blood, in the second, the right of soil) and to different state practices regarding multiple citizenships (rejection vs tolerance). Since then, the idea of the nation has become so important that state constructions around the world are largely based on it. From an intellectual construct, the nation has become a concrete object through the history and functioning of states. By examining this object through the lens of nationality laws, but also through the practices and representations of the actors involved, this topical collection allows us to approach the nation in the making, in the everyday, a question that would otherwise remain elusive. Indeed, it is at the intersection of state and individual logics that we can better grasp the idea of the nation, as demonstrated by the perspective of the Japanese case treated by Eline Delmarcelle and the Chinese case treated by Paul May. Although neither state tolerates multiple citizenships, in the former, naturalized citizens reluctantly comply with the injunction to give up their original citizenship in the hope of being perceived as “good Japanese”, while Chinese citizens who take Canadian nationality as an investment seem to have no great difficulty in doing so. This tells us something about the tacit integration of the hierarchy between citizenships by the actors involved, and the ways in which they absorb and then translate, or not, in their actions and words, the representations of the nation in force in their country of origin or adoption.
