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Beyond a state-centric perspective on norm change: a multilevel governance analysis of the retreat from multiculturalism.

This article argues that constructivist literature on norm diffusion could benefit from using a multilevel governance perspective. The case study is a retreat from the multicultural approach to governing state-minority relations in liberal democratic states, focusing on Canada and the Netherlands. It argues that, although actors at the national level may be retreating from the norms underlying this multicultural approach, this is not true of the substate and suprastate levels. Instead, in both countries, there is evidence of work at these levels to maintain these norms. Keywords: multiculturalism, multilevel governance, Canada, the Netherlands.


In THIS ARTICLE I ARGUE that existing constructivist literature on norm diffusion relies too heavily on examinations of the national level of governance to gauge norm diffusion, and would benefit from incorporating a multilevel governance perspective. I take the retreat from the multicultural approach to governing state-minority relations and its underlying norms as a case study, focusing on Canada and the Netherlands. This is an example of a norm that has been influential on liberal democratic states, and is deeply connected to global human rights norms.

Multiculturalism is a term that is often misunderstood. It is sometimes used descriptively, to refer to diversity in a society. It is also used to refer to specific policies of accommodating ethnocultural minorities, or to theories about how states should act to ensure that minorities are treated justly. (1) I argue that multiculturalism also represents a broader normative approach to governing diversity, which restricts how liberal democratic states are expected to treat ethnocultural minorities in their populations. It is this broader multicultural approach with which this article is concerned.

This multicultural approach to governing diversity represents a break with older approaches, in which "ethnic diversity was seen primarily as a threat to social and political order, and ... was actively discouraged by the state." (2) This new approach emerged in the post-World War II period and was rooted in human rights norms of equal human dignity. (3) When I refer to "the multicultural approach," I refer to an approach to governing ethnocultural diversity that dictates that states not only must tolerate ethnocultural diversity but also must actively protect equality.

There is scholarly debate about whether a shift away from multiculturalism is occurring. Some see the shifts away from multicultural policies as evidence of an assimilationist turn. (4) Will Kymlicka disagrees, arguing that multiculturalism is not in retreat and that much of this debate misunderstands what multiculturalism is. (5)

In this article, I focus not on a particular multicultural policy, but on the possible shift from the multicultural approach and its underlying norms. This is a case of how an existing global norm--of how liberal democratic states should govern ethnoculturally diverse populations--is changing. It is also a case in which a state-centric perspective on norm change is less useful than a multilevel governance perspective, which is open to the notion that the state is not the only (or the most important) actor involved in governing such issues.

I suggest that by paying attention to other levels of governance it becomes apparent that although actors at the national level may be retreating from the norms underlying multiculturalism, this is not true of the substate and suprastate levels. Instead, in Canada and in the Netherlands, there is evidence of efforts at these other levels (both governmental and nongovernmental) to maintain a multicultural approach to governing ethnocultural diversity and to work against the national level's retreat from it. Constructivist studies of norm diffusion tend either to treat national-level acceptance of norms as evidence of successful diffusion, or to consider the substate level merely because of how it influences this state-level acceptance of new norms. I suggest that a multilevel governance perspective adds a new dimension to such studies and may lead to different answers.

Canada and the Netherlands are states in which the norms of multiculturalism are well established. (6) Yet both have altered their multiculturalism policies in the wake of public debates critical of multiculturalism. These criticisms have focused heavily on policies aimed at one type of minority: immigrants. Existing scholarship on this retreat from multiculturalism has analyzed how national governments have reacted to such criticisms, but to my knowledge few have examined how substate or suprastate actors have responded.

I selected one city to study in each of these two countries: Mississauga in Canada and Utrecht in the Netherlands. These cities were selected because they have substantial diversity in their populations without being the most diverse city in their country. Within Canada, Mississauga had about the sixth most diverse population within Canada, (7) and Utrecht had about the fourth most diverse population in the Netherlands. (8) As such, each city had enough diversity to expect that there would be measures in place to govern it, but neither represented the highest levels of diversity in their country. I also examined suprastate bodies associated with Canada and the Netherlands.

The Constructivist Literature on Norm Diffusion

Some social constructivist literature focuses on the process of norm diffusion, or the process of change to the norms that constitute actors' identities and interests. As mentioned above, the norms of the multicultural approach dictate the boundaries of how liberal democracies are expected to govern ethnocultural diversity, but questions have arisen about whether this normative consensus is unraveling.

There are two waves of constructivist literature on norm diffusion. The first wave focuses heavily on cases in which states adopted foreign norms. Key examples of this wave include the work of Martha Finnemore, Michael Barnett, Peter Katzenstein, and Margaret Keck and Kathryn Sikkink, all of which examined cases of international norms and transnational actors shaping state interests. (9) Amitav Acharya points out that this wave of scholarship is focused on conversion to new norms rather than contestation between existing and new norms. (10)

As opposed to the first wave of constructivist scholarship, the second wave focuses on the agency (and structures) involved at the domestic level in cases of normative change. Examples of this wave include Acharya's work as well as that by Jeffrey T. Checkel and Jeffrey W. Legro. Checkel says the first wave of constructivist work lacks a theory of the domestic agency of "norm takers," overpredicts the influence of international norms, and cannot explain the variation between different states' reception to foreign norms. (11) He argues that certain domestic conditions can predict whether a norm will be successfully integrated in particular states; namely, the political structures of those states and the "cultural match" between local norms and the foreign norm under examination. Similarly, Legro's concept of organizational culture emphasizes the importance of domestic conditions in the process of norm adoption. (12)

Acharya criticizes Checkel's cultural match concept, and Legro's theory of the role of organizational culture for being too static and proposes his own theory of the dynamic interaction between local norms and new norms in the process of norm change. He calls this "constitutive localization," suggesting that local actors go beyond framing foreign norms in a favorable way, or grafting them onto local norms, and actually reconstitute foreign norms and local norms in order to make them congruent with each other. (13)

Although the second wave of this literature adds a great deal by delving into the domestic factors that contribute to norm change, the two waves have some assumptions in common that limit their ability to address the cases that I examine in this article. First, both are focused heavily on the adoption of new norms, rather than the question of retreats from (or contestation over) well-established norms. Second, both assume that the definitive test of a norm's successful adoption is state-level acceptance of that norm. Although the first wave of literature is firmly focused on this state level, the second wave tends to explore substate factors as a way of understanding how and why a norm comes to be adopted by state-level actors. In other words, the case of a possible retreat from the norms of the multicultural approach do not fit this mold. Given that these cases show that the norms underlying multiculturalism have fallen out of favor at the national level of governance but not at the sub- or suprastate levels, the norm diffusion literature may be limiting itself by focusing mainly on state adoption of norms as a measure of successful norm change.

A Multilevel Governance Analysis of the Retreat from Multiculturalism in Canada and the Netherlands

In recent years, there have been many dramatic declarations of the failure of multiculturalism, but not all have come from countries that were committed to policies based on a multicultural approach. Canada and the Netherlands provide interesting cases of the trajectory of the norms underlying this approach because these norms were internalized in each country, yet both have been impacted by public debates critical of multiculturalism. I argue that a multilevel governance analysis shows that these are not simple cases of a retreat from multiculturalism.

In this section I provide more detail about the multicultural approach and its underlying norms, and then examine the cases of Canada and the Netherlands.

The Multicultural Approach and Its Underlying Norms

There is a great deal of scholarly literature on multiculturalism, and much of it focuses either on the theory of multiculturalism or its implementation at the national level or subnational level. Few studies have explored the multicultural approach through a multilevel governance perspective. In order to do so, I examined my cases using a conceptualization of multiculturalism--which as mentioned above I call the multicultural approach to governing ethnocultural diversity--that focuses on its underlying norms and how they dictate a particular approach to governing diversity.

This approach departs from previous ways of conceptualizing not only state-minority relations, but also national unity and identity. Older methods of assimilating, excluding, or marginalizing minorities are no longer acceptable for liberal democracies. Instead, such states must govern in ways that conform to the normative foundation of the multicultural approach, which means not only tolerating ethnocultural diversity but also protecting equality--not in a difference-blind manner, but by extending public recognition and support for minority cultural identities. (14)

Many scholars of multiculturalism identify this normative shift in state-minority relations in the post-World War II period, and connect it to the rise of human rights at this time. Triadafilos Triadafilopoulos suggests that the emergence of multiculturalist integration policies for immigrants was embedded in "the broader liberalizing trend that has been unfolding since the end of World War II," and "liberal-democratic states' rejection of the explicitly racist policies and mindsets that were common in the pre-WWII era." (15) Others, such as Kymlicka, Charles Taylor, Christian Joppke, and Gerard Bouchard also associate the emergence of multiculturalism with the rise in human rights discourse in the postwar period. (16) Kymlicka argues that "the human rights revolution unleashed a set of ideas about ethnic and racial equality, and a set of political movements contesting ethnic and racial hierarchies, that led naturally to contemporary struggles for multiculturalism and minority rights." (17)

The multicultural approach means accepting ethnocultural diversity and governing a diverse population in a way that extends recognition and accommodation to different ethnocultural groups. This recognition and accommodation implies that difference-blind means of protecting equality are not sufficient because they do not recognize diversity and have the potential to reinforce the dominance of the majority.

I argue that the normative foundation of multiculturalism, then, consists of (1) repudiating older schemes of governing diversity that relied on assimilation, exclusion, or marginalization of those not part of the dominant racial or ethnocultural groups; (2) respecting the principles of the protection of equality, culture, and freedom of religion--that are based on the human rights to these principles; and (3) conceiving of national identity as something that includes ethnocultural diversity.

Multiculturalism in Canada and the Netherlands

Canada. Canada's multiculturalism program is a federal program that is largely implemented by nonstate actors at the substate level. Although the structure of the program has remained fairly stable since its creation, the policy objectives and priorities have changed considerably in response to criticisms and debates about multiculturalism. (18)

In 1971, Canada declared a policy of multiculturalism with the following objectives: (1) assisting cultural groups to retain and foster their identity; (2) assisting cultural groups to overcome barriers to their full participation in Canadian society; (3) promoting creative exchanges among all Canadian cultural groups; and (4) assisting immigrants in acquiring at least one of the official languages. (19) These objectives have changed considerably. In the 1980s, multiculturalism was institutionalized in the 1982 Constitution, the 1988 Canadian Multiculturalism Act, and the creation of a Multiculturalism and Citizenship Department in 1991. (20) In the 1990s, there were examples of political rhetoric critical of the multiculturalism policy.

For instance, the federal Progressive Conservative Party voted at their 1991 biennial convention to "abandon the policy of multiculturalism and instead try to foster a common national identity." (21) However, it was the Liberal government that acted on such criticisms, dismantling the Multiculturalism and Citizenship Department in 1993 and moving the multiculturalism program to the Department of Canadian Heritage. (22) This move was also motivated by two reports that found substantial negative public opinion about the multiculturalism program. Both the Spicer Report in 1991 and the Brighton Report in 1996 found that Canadians were supportive of cultural diversity and multiculturalism but not the activities of the multiculturalism program, which were perceived as catering to "special interests." (23) The Brighton Report recommended focusing the program on goals that all Canadians could identify with, such as integration and social cohesion, (24) and this has been reflected in the policy objectives issued since 1996 that focus on ensuring that immigrants are not hindered from participating in Canadian society because of their ethnocultural or racial difference. (25) When the program's objectives were updated by the governing Conservative Party in 2010 (with its move into the Department of Citizenship and Immigration [CIC]), social cohesion was added as a key goal and the program was positioned as part of the immigrant integration process, rather than as an element of Canada's overall cultural development. (26) As well, the 2010 funding guidelines for the multiculturalism program specified that it would not fund cultural or heritage language events or initiatives. (27) The guidelines explained instead that the program would fund initiatives fostering social cohesion and the integration of immigrants into Canadian society.

The Conservative minister of CIC at that time, Jason Kenney, made a number of statements that indicated that the program was primarily intended to facilitate integration of immigrants into Canadian society. For example, he explained to a Canadian national newspaper, the National Post: "We want to avoid the kind of ethnic enclaves or parallel communities that exist in some European countries. ... I think it's going to require a greater effort in the future to make sure that we have an approach to pluralism and immigration that leads to social cohesion rather than fracturing." (28) He also suggested in a March 2009 speech that multiculturalism should shift back to the way it was conceptualized in the 1960s by Senator Paul Yucek--as multiculturalism in the context of the French, British, and Aboriginal traditions that were "the foundations of any genuine Canadian identity." (29) As well, he sparked a public debate when he declared that as of December 2011, newcomers would be required take the citizenship oath without wearing face-covering clothing such as niqabs. He said this was in response to complaints that such women could not be seen reciting the citizenship oath. Kenney said that to allow women to wear niqabs to citizenship ceremonies was akin to tolerating "two classes of citizens." (30)

Yet as the Conservative Party was changing the content of multicultural policies and shifting their rhetorical treatment of these policies, they were also investing energy into building ties with ethnic communities. This was a bid to cast themselves as supporters of multiculturalism while simultaneously reframing the policy. Kenney, the minister largely responsible for building support among ethnic groups in Canada, had spearheaded the effort to expand the Conservative Party's base of supporters by appealing to Canada's fastest-growing demographic--immigrants. (31) In fact, when the Conservatives achieved a majority government in 2011, it was attributed in part to their substantial gains in seats in Canada's largest urban center--the Greater Toronto Area--which includes a high population of immigrants. (32)

Despite the rhetoric deployed to win support from ethnic communities, the multiculturalism that the Conservative Party loudly supported was fairly superficial and not necessarily connected to the policy changes to the multiculturalism policy itself. Canada did not eliminate its multiculturalism policy or disavow support for it, but a closer look reveals that the substance of this policy was reshaped.

At the national level of governance, the federal policy of multiculturalism was gradually shifted from its original focus on the recognition and accommodation of ethnocultural minorities to a focus on immigrant integration. Although integration was part of the original objectives, this has been emphasized and the priority given to cultural accommodation has been reduced. The policy objectives for the multiculturalism program have eliminated references to celebrating and encouraging cultural diversity, and the program no longer funds ethnospecific initiatives to accommodate or recognize minority cultures.

Yet this trend was not reflected at the substate level. Municipal governments were involved in implementing the federal immigrant settlement program, and their approach to doing so has maintained many aspects of the norms of the multicultural approach that the national level eliminated. Mississauga, the Canadian city that I used as a case study, was active in pursuing its own initiatives to accommodate ethnocultural diversity. The municipal government with jurisdiction over Mississauga--the Peel Regional Government--created an internal diversity policy, ran programs to help immigrants access the labor market, and initiated a project to study the effects of Peel's diverse population. Such goals were reflected in Peel's Vision and Mission for 2007-2010 and the Diversity and Inclusion Strategy, both of which pledged to treat diversity as a valuable asset to be nurtured. (33)

One of the most ambitious projects that the Peel government participated in was the Peel Newcomer Strategy Group (PNSG), a collaborative project to study the immigrant integration process in the Peel region and develop a model of improved settlement service delivery. The PNSG report recommended that there was a need for more cultural sensitivity by the settlement services sector and increased efforts to make services accessible to ethnocultural minorities. The Peel government partnered with nongovernmental organizations (NGOs) to create the project and solicited the involvement of representatives of other levels of government, local businesses, school boards, universities, and many civil society organizations. (34) This project was one of the first Local Integration Partnerships (LIPs) in Canada, and it successfully won federal government funding. Such examples demonstrate how the local level not only pursued projects that promoted a multicultural approach, but local actors were sometimes able to push up to the federal level to solicit support.

Mississauga's NGOs also did not follow the federal government's lead in their implementation of the federal settlement program. Although the federal program was explicitly aimed at integrating immigrants, the NGOs did so in a way that reserved an important place for the recognition and accommodation of minority ethnocultural identities. Many programs included ethno-specific workshops and activities--precisely the type of events that the federal multiculturalism program explicitly characterized as ineligible for funding.

In addition, many mainstream organizations also pursued ambitious diversity policies and outreach activities. The police in the Peel region, as well as institutions like hospitals and school boards, made cultural sensitivity and intercultural dialogue a central aspect of their operations.

Whereas the federal government established its multicultural policy and subsequently reframed it in such a way that the recognition and accommodation of ethnocultural difference was reduced, in Mississauga there were many initiatives to study, plan for, and accommodate diversity. The assumption shared by these local actors was that recognition and accommodation of diversity were a practical necessity.

The Netherlands. At the Dutch national level, the central government's reaction against multiculturalism was much more dramatic than Canada's. The Dutch multicultural policy--called the Ethnic Minorities (EM) Policy of 1983--was replaced in 1998 with mandatory immigrant integration laws. The central government shifted to an official position of disowning multiculturalism, saying: "The government wants to abandon the idea of a 'multicultural society.' Dutch society is constantly changing, in part under the influence of other cultures, but it has its own character and is not interchangeable." (35) The central government is responsible for the immigration and integration programs, but it delegates important aspects of the implementation of the integration program to city governments.

The 1983 EM Policy involved the creation of antidiscrimination legislation; establishing voting rights in 1985 for legal residents (who were not yet citizens); altering nationality law in 1986 to include more elements of ius soli; creating consultation structures with ethnocultural groups; establishing training courses to boost minority employment; forming voluntary agreements with employers to encourage the hiring of minorities; and creating a system in which schools received extra funding if they had higher numbers of minority students. (36) The EM Policy was the target of much criticism and public debate. A critical report released by the Scientific Council for Government Policy in 1989 was the catalyst for its replacement with a policy of mandatory integration for immigrants and the 1998 Integration of Newcomers Act. (37)

Much of the public criticism of multiculturalism in the Netherlands was focused on the perceived challenges of integrating Muslim immigrants. Paul Scheffer argues in his 2000 essay in the Dutch national newspaper NRC Handelsblad that multiculturalism was a failure and that the solution should be to adopt an assimilationist policy and a "civilization offensive" against immigrants (particularly Muslims) with illiberal and non-Western values. (38) Pim Fortuyn's statements about multiculturalism went as far as to call for a "cold war against Islam," and his Lijst Pim Fortuyn party won an unexpected number of votes in national elections. (39)

Two murders added to the urgency of debate about multiculturalism. In 2002 Fortuyn was murdered (for reasons unrelated to his criticism of immigration), and in 2004 another man who was well known for his criticism of Muslim minorities in the Netherlands was killed, this time by a Dutch-born young Muslim man of Moroccan descent. The victim was Theo van Gogh, a filmmaker who had recently released a film that criticized Islam's treatment of women.

The next wave of immigrant integration legislation included the 2006 Civic Integration Abroad Act and the 2007 Integration of Newcomers Act. The Civic Integration Abroad Act required that certain migrants pass an integration exam before entry into the Netherlands: those defined as "non-Western" by Dutch statistics. This category included those coming from outside of the European Union (EU), the European Economic Community, or the states with which the Netherlands had bilateral immigration agreements (Australia, Switzerland, Canada, Japan, New Zealand, South Korea, and the United States). (40) After entry in the Netherlands, immigrants were required to follow the integration program as laid out by the Integration of Newcomers Act. However, in addition to new immigrants, the program was also mandatory for the so-called oldcomers--immigrants who had settled and lived in the Netherlands for many years but who had never obtained citizenship. (41) The 2006 and 2007 laws required that the integration exams test not only knowledge of Dutch language, history, and institutions, but also Dutch society and culture.

The elimination of the EM Policy did not blunt the critical rhetoric by national political actors. Geert Wilders, the leader of the Freedom Party (PVV), became well known for his criticism of multiculturalism and his assertion that accommodating Muslim immigrants posed a threat to Dutch society. He exclaimed to the Dutch newspaper De Volkskrant in 2004: "Why are we afraid to say that Muslims should adapt to us, because our values are simply of a higher, better, more pleasant and humane level of human civilization? No integration; assimilation!" (42) In the 2010 election, Wilders's party won enough seats to be included in a formal agreement to support the governing coalition. The Dutch electoral system--which uses proportional representation--allows marginal political parties, such as the PVV, the opportunity to enter into the mainstream. (43)

After the mid-1990s, the Dutch central government's approach to governing immigrant diversity was markedly changed. Recognition or accommodation of ethnocultural minorities was deliberately eliminated and denounced, difference-blind approaches to the protection of equality became common, and the integration program established an atmosphere in which many members of ethnocultural minority groups felt marginalized.

Despite these developments at the Dutch national level, in the city of Utrecht there was a very different reaction to public debate about multiculturalism by both the local government and nonstate actors. At the same time that the central government was introducing the 2006 and 2007 integration acts, Utrecht's government was implementing its Diversity and Integration Program that included as one of its goals "making the value of diversity evident." (44)

The Utrecht government was responsible for implementing many aspects of the national integration law, such as monitoring whether the inburgeraars (the Dutch term for all types of people who are required to pass integration exams) completed the exam within the specified time limit, collecting the fine for inburgeraars who did not meet these requirements, and contracting nongovernmental organizations to provide integration courses. (45)

Several of the initiatives of the Utrecht government went against the central government's assertion that inburgeraars should be responsible for their own integration and cover the cost of the integration exams. For example, Utrecht reimbursed the cost of the integration exams for inburgeraars in the city. The Utrecht government also maintained an internal diversity policy and created an alliance of Utrecht employers to support organizations in establishing diversity policies. Utrecht stipulated that any organizations subsidized by the city government or contracted for goods or services by it were required to have "an active diversity policy." (46)

An example of a direct refusal to comply with the national government's directives is that of integration classes for women in Utrecht. Some women-only classes were offered for women with Islamic beliefs that required avoiding contact with men. In 2009, of the 100 integration classes offered in Utrecht, 12 were women-only classes. (47) This drew criticism from then central government integration minister Eberhard van der Laan. He said the classes amounted to segregation, and argued that gender equality was a basic value of Dutch society that should not be compromised by offering women-only classes. Radio Netherlands reported that "Utrecht city counselor Marka Spit says she is going to ignore Dutch Integration Minister Ebhard van der Laan's plan to abolish segregated integration courses." (48) The courses were continued, but in an unofficial manner. Although there were no formal women's classes after this confrontation, Muslim women were informally grouped together in classes. Spit explained to local media that the integration classes would include lessons on the rights and responsibilities of individuals in Dutch society, including gender equality rights, but that if these women were not comfortable attending class they would never benefit from such information.

In a context in which multiculturalism has been declared a complete failure at the national level, the Utrecht city government maintained a surprising number of programs that were supportive of diversity and at odds with the approach taken by the central government. There were also many nongovernmental organizations that played an important role in the governance of immigrant diversity. An example is Movisie, the Netherlands Centre for Social Development. One of Movisie's programs was aimed at helping immigrant women who were isolated in their homes by directing them to resources to learn the Dutch language, obtain job training, and facilitate their participation in their communities. Movisie also collected information about successful strategies for doing this, which it compiled into a database. The center used this information to consult with many city governments, including Utrecht's, to develop strategies for supporting immigrants.

These examples show a clear difference between the national and substate levels. The shift away from the multicultural approach and its underlying norms was more dramatic at the Dutch national level than in the Canadian case, yet both cities showed evidence of resistance to the leadership by their national governments. In fact, Utrecht not only promoted unpopular ideas and programs, but also directly undermined or refused to carry out parts of the national integration program.

The suprastate level. Within each state, there is contestation between different levels of government over the normative approach to governing immigrant diversity. At the suprastate level, there are some initiatives of international organizations that provide normative guidance to states on the governance of immigrant diversity, and they tend to align with the approaches taken at the substate rather than the national levels. Although there is little evidence of a direct connection between these organizations and the cities that I examined, this suggests that the contestation over this norm goes beyond the borders of particular states.

Many would assume that there are no global norms of the governance of immigrant ethnocultural diversity, let alone multiculturalism. Alexandra Xanthaki explains that "although the scarcity of references to the term 'multiculturalism' suggest otherwise, on closer inspection, current human rights law endorses the components of multicultural policies and reflects a multicultural vision." (49) Kymlicka believes that the adoption of multiculturalism "has been both inspired and constrained by human rights ideals. (50) As such, some UN human rights standards are relevant when discussing norms of the governance of diversity.

Both Canada and the Netherlands have obligations to supranational organizations. Both countries are subject to the human rights standards at the UN level. At the regional level, Canada is a member of the Organization of American States (OAS) and is subject to the American Declaration on the Rights and Duties of Man (1948) but, because it has not ratified the American Convention on Human Rights (1948), it is not subject to the jurisdiction of the Inter-American Court of Human Rights. The Netherlands is a member of the EU and the Council of Europe (CoE) and, as such, is subject to the regional layer of law and policy. It is party to the CoE's European Convention on Human Rights (ECHR) and falls under the jurisdiction of the European Court of Human Rights.

At the UN level, the Committee on Economic, Social, and Cultural Rights has commented on state obligations with respect to governing minorities, saying: "Any programme intended to promote the constructive integration of minorities and persons belonging to minorities into the society of a State party should thus be based on inclusion, participation and non-discrimination, with a view to preserving the distinctive character of minority cultures." (51) This committee also established an independent expert in the field of cultural rights in 2009. The approach promoted by such initiatives appears to be similar to those taken at the substate rather than the national level.

Several initiatives by European regional organizations also promote such an approach. One example is the EU Common Basic Principles (CBPs) on immigrant integration. The CBPs promote the idea of integration as a "dynamic, two-way process of mutual accommodation by all immigrants and residents of Member States." (52) The CBPs also include the principle that basic knowledge about the receiving country's language, history, and institutions is necessary for the integration of immigrants, but that "full respect for the immigrants' and their descendants' own language and culture should be also an important element of integration policy." (53)

An example of CoE policy on the topic is the Faro Declaration, which emerged from the October 2005 CoE meeting of the ministers responsible for cultural affairs. The declaration states that "we reject the idea of a clash of civilisations and firmly believe that, on the contrary, increased commitment to cultural cooperation--in the broad sense of the term--and intercultural dialogue, will benefit peace and international stability in the long term." (54) It asserts that intercultural communication was the path to "an integrated and cohesive society." (55) The follow-up to this declaration is the White Paper on Intercultural Dialogue, which promotes "an open and respectful exchange of views between individuals, groups with different ethnic, cultural, religious and linguistic background and heritage on the basis of mutual understanding and respect." (56) Rather than mandatory integration and insistence on the dominant groups' norms and values, the white paper encourages mutually respectful dialogue. Such an approach appears to maintain and build on the norms of multiculturalism rather than departing from them.

In general, the relevant international and regional levels of governance associated with Canada and the Netherlands did not retreat from promoting a multicultural approach to the governance of immigrant ethnocultural diversity and, instead, the references toward respecting minority cultural identity and promoting intercultural understanding suggest that the approach taken at this level remains grounded in the norms of the multicultural approach.


A multilevel governance perspective shows that the retreat from multiculturalism is not as clear-cut as it is often portrayed. Although the national governments in Canada and the Netherlands both show signs of a move away from the multicultural approach and its underlying norms--albeit to different degrees and in different ways--the substate actors that I examined in each country did not follow along. Instead, the city governments and nonstate actors involved in the governance of immigrant ethnocultural diversity used their jurisdiction over integration and settlement programs to maintain a multicultural approach and the protection of cultural and religious diversity in a group-differentiated way. In addition, at the suprastate level, there are important initiatives that respond to debates about multiculturalism without retreating from these norms. Thus, whereas the norm of how liberal democracies should govern immigrant diversity may indeed be changing, it is not a simple retreat from multiculturalism that is taking place. Instead, a multilevel governance perspective suggests that some actors are promoting a retreat and others are pushing for new ways of understanding and implementing the norms of multiculturalism. A multilevel governance perspective provides a more comprehensive understanding of how actors in each case have responded to the criticisms of multiculturalism, but it also sheds light on the broader question of how normative change occurs.

The constructivist literature on norm diffusion tends to assume that states are the main gatekeepers of normative change but these cases show that, if we peel apart the levels of governance, it becomes apparent that other levels can play key roles. Finnemore and Sikkink's influential norm life cycle theory rests on the assumption that norm internalization can be measured by the number of state adherents to a new norm, but this does not necessarily take into account the role that nonstate and substate actors can play in the process of norm adoption and contestation. (57)

As I discussed, the second wave of this literature places more emphasis on the agency of domestic, or substate, actors in the process of norm diffusion. Checkel criticizes the first wave of literature for assuming an "epidemic or epidemiological model" of norm diffusion by which simple contact with a norm causes it to spread. (58) He argues that the domestic contexts, as well as the agency of domestic actors, are factors that must be considered to understand how and why norms do (or do not) spread. Also, Acharya's theory of constitutive localization emphasizes the role these domestic agents play in reconstituting global norms to make them more amenable to be adopted in a particular state. (59)

Although this literature makes important strides by insisting that the agency of substate and nonstate actors is crucial to norm diffusion, it still uses state adoption of norms as the determinant of a norm's influence. In addition, the focus of this second wave constructivist work remains state adoption of new norms, not normative change that involves contestation and evolution of existing norms.

The Canadian and Dutch cases are examples of normative change involving a set of existing norms that are the subject of contestation between different levels of governance. These are cases of norms being interpreted and refined at sub- and suprastate levels in ways that challenge and defy the direction taken by the national-level government. For example, Utrecht's municipal government used its jurisdiction over the implementation of integration programs to maintain a multicultural approach by injecting measures to make these programs more culturally sensitive and accessible. Nonstate actors such as those in Mississauga placed a great deal of importance on carrying out settlement policies in ways that maintain the norms of a multicultural approach. In both cases there were some examples of initiatives at the substate level that pressed for the national level to either change its approach or provide support for the substate approach. Examples of this include Mississauga's PNSG project, which influenced the creation of the LIP program in Canada, and the public refusal of Utrecht's government to comply with some aspects of the national-level integration program. (60)

This is a case of a national-level backlash against an existing norm and the contestation that has taken place over how it should be reinterpreted. Although the norms underlying multiculturalism were not necessarily internalized globally--it is chiefly liberal democratic states with diverse populations that are expected to adhere to these norms--the backlash against multiculturalism does provide an interesting example of what happens after a norm has been internalized by a significant portion of the international community.

The substate approach in the cities that I examined maintains and builds on these norms in a way similar to what Acharya calls "constitutive localization," or what Susanne Zwingel calls the "contextualized appropriation" of norms. (61) Building on the work of Maila Stivens and Brooke A. Ackerly, Zwingel argues that global norms must be reinterpreted in the context of local practices without falling victim to complete cultural relativism, thus "the legitimacy and authority of global norms depends on their active interpretation and appropriation within national and local contexts all over the world." (62) Similarly, the contestation over these norms may be seen as part of a process of what Seyla Benhabib calls "democratic iterations," by which the meaning of norms are actively reinterpreted as they are used repeatedly. Benhabib explains that "every iteration involves making sense of an authoritative original in a new and different context. The antecedent thereby is reposited and resignified via subsequent usages and references." (63) Simply by engaging with or drawing on these norms, actors at different levels may reinterpret them in a way that suits their particular context and interests.

In other words, global norms are abstract standards of appropriate behavior that can have real influence only through their interface with local contexts and practical interpretations. As Acharya puts it, local actors or "insider proponents" of global norms must work to make these norms congruent with existing local normative standards in order to facilitate their successful adoption. (64) In my two cases, however, Utrecht and Mississauga are not acting as proponents of new norms, but as opponents of a retreat from existing norms and proponents of a reinterpretation to revive these existing norms. They are what might be called "insider opponents" to the national level.

An interesting result of this contestation is that cities are increasingly networking with other cities to collaborate on strategies for the governance of immigrant integration. Networks such as the Intercultural Cities program (of the Council of Europe) and the Cities of Migration initiative (of Maytree in Canada) are examples of such collaborative projects. Mississauga and Utrecht were not deeply involved in these initiatives at the time of this writing, but they are good examples of how this normative contestation may be spawning new (less state-centric) governance approaches nonetheless.

In sum, these cases provide an example of normative change that is not fully explained by the existing norm diffusion literature. It is an example of contestation between levels of governance that responds to debates about immigration and multiculturalism, and includes some that promote a retreat from existing norms and some that wish to maintain and further develop them. Thus, it shows that norm change can occur in a way that is not necessarily as state centric as much of the constructivist literature on norm diffusion assumes. Instead, different levels of governance (including some nonstate actors) play important roles and even implement alternative normative approaches. The interplay between the levels is important, and not only because of the part that substate actors play in causing states to adopt new norms. At the same time, cities like Utrecht and Mississauga are acting to revive and reinterpret the norms that underlie the multicultural approach, and develop a more effective approach that maintains these underlying norms. This suggests that a multilevel governance approach may contribute to a fuller understanding of norm change.


Laura Reidel completed her PhD in global governance at the Balsillie School of International Affairs in 2013 and is presently a Balsillie School Fellow.

(1.) One prominent example of a study of multicultural policies is the Multiculturalism Policy Index, created by Will Kymlicka and Keith Banting. This index stipulates that the following are policies consistent with common use of the term "multiculturalism" with respect to immigrant minorities: (1) constitutional, legislative, or parliamentary affirmations of multiculturalism; (2) the adoption of multiculturalism in school curricula; (3) the inclusion of ethnic representation or sensitivity in the mandate of public media or media licensing; (4) exemptions from dress codes, Sunday-closing legislation, and so forth; (5) allowance of dual citizenship; (6) the funding of ethnic group organizations to support cultural activities; (7) the funding of bilingual education or mother tongue instruction; and (8) affirmative action for disadvantaged immigrant groups. Multiculturalism Policy Index,, accessed 7 February 2014.

(2.) Stuart N. Soroka, Richard Johnston, and Keith Banting, "Ties that Bind? Social Cohesion and Diversity in Canada," in Keith Banting, Thomas J. Courchene, and F. Leslie Seidle, eds., Belonging: Diversity, Recognition and Shared Citizenship in Canada (Montreal, QC: Institute for Public Policy, 2007), p. 561.

(3.) There is broad scholarly consensus about the idea that the normative foundations of multiculturalism are rooted in global human rights norms. See, for example, Will Kymlicka, Multicultural Odysseys: Navigating the New International Politics of Diversity (Oxford: Oxford University Press, 2007); Triadafilos Triadafilopoulos, "Illiberal Means to Liberal Ends? Understanding Recent Immigrant Integration Policies in Europe," Journal of Ethnic and Migration Studies 37, no. 6 (2011): 861-880; Christian Joppke, "Immigrants and Civic Integration in Europe," in Keith Banting, Thomas J. Courchene, and F. Leslie Seidle, eds., Belonging: Diversity, Recognition and Shared Citizenship in Canada (Montreal, QC: Institute for Public Policy Research, 2007); Charles Taylor, Multiculturalism and "The Politics of Recognition": An Essay (Princeton: Princeton University Press, 1992); Gerard Bouchard, "What Is Interculturalism?" McGill Law Journal 56, no. 2 (2011): 435-468.

(4.) Ellie Vasta, "From Ethnic Minorities to Ethnic Majority Policy: Multiculturalism and the Shift to Assimilationism in the Netherlands," Ethnic and Racial Studies 30, no. 5 (2007): 713-740; Rogers Brubaker, "The Return of Assimilation? Changing Perspectives on Immigration and Its Sequels in France, Germany and the United States," Ethnic and Racial Studies 24, no. 4 (2001): 531-548; Triadafilopoulos, "Illiberal Means to Liberal Ends?"

(5.) Will Kymlicka, "Multiculturalism: Success, Failure, and the Future," Migration Policy Index, 2012, -success-failure.

(6.) One exception to the Canadian case is the province of Quebec, where the federal government's policy of multiculturalism was rejected. This particular dimension of the Canadian case, although it is an important topic for future research, fell outside of the scope of this study. The focus was on one city in each country and, within Canada, a Quebecois city was not selected. An important starting point for this study is whether a retreat has taken place from the multicultural approach, and this question becomes more complicated with a province that never accepted this approach.

(7.) Statistics Canada, Visible Minority Groups, 2006 Counts, for Canada and Census Subdivisions (Municipalities) with 5,000-plus Population, 2006, www12.statcan .ca/census-recensement/2006/dp-pd/hlt/97-562/pages/page.cfm?Lang=E&Geo=CSD &Code=01 &Table= 1 &Data=Count&StartRec= 1 &EndRec=692&Sort=2&Display =All&CSDFilter=5000, accessed 6 February 2013.

(8.) Utrecht Administrative Information Department, The City of Utrecht, 2008,, accessed April 2009.

(9.) Martha Finnemore, National Interests in International Society (Ithaca: Cornell University Press, 1996); Michael N. Barnett and Martha Finnemore, Rules for the World: International Organizations in Global Politics (Ithaca: Cornell University Press, 2004); Peter Katzenstein, The Culture of National Security: Norms and Identity in World Politics (New York: Columbia University Press, 1996); Margaret Keck and Kathryn Sikkink, Activists Beyond Borders: Advocacy Networks in International Politics (Ithaca: Cornell University Press, 1998).

(10.) Amitav Acharya, Whose Ideas Matter? Agency and Power in Asian Regionalism (Ithaca: Cornell University Press, 2009), pp. 9-10.

(11.) Jeffrey T. Checkel uses the terms "norm-maker" and "norm-taker" to describe actors that pioneer norms and those that adopt them. Jeffrey T. Checkel, "Norms, Institutions, and National Identity in Contemporary Europe," International Studies Quarterly 43, no. 1 (1999): 83-114, at 85.

(12.) Jeffrey W. Legro, "Which Norms Matter? Revisiting the 'Failure' of Internationalism," International Organization 51, no. 1 (1997): 31-63.

(13.) Acharya, Whose Ideas Matter?

(14.) A difference-blind approach is one that affords the same rights to everyone regardless of gender, race, or other such factors. Such an approach risks reinforcing the dominant group's customs and traditions and puts minorities at a disadvantage.

(15.) Triadafilopoulos, "Illiberal Means to Liberal Ends?" pp. 864-865.

(16.) Kymlicka, Multicultural Odysseys; Taylor, Multiculturalism and "The Politics of Recognition"; Joppke, "Immigrants and Civic Integration in Europe"; Bouchard, "What Is Interculturalism?"

(17.) Kymlicka, Multicultural Odysseys, p. 88.

(18.) The basic structure of the program consists of three streams: (1) a grants and contributions program, which funds nongovernmental projects relating to multiculturalism; (2) a public education and outreach program; and (3) efforts to support federal institutions in incorporating awareness of multiculturalism within government departments.

(19.) Michael Dewing and Marc Leman, Canadian Multiculturalism, Parliamentary Information and Research Service, Parliament of Canada, 2006,

(20.) Section 27, Canadian Charter of Rights and Freedoms. "This Charter shall be interpreted in a manner consistent with the preservation and enhancement of the multicultural heritage of Canada."

(21.) Carol Goar, "One Final Appeal for Multiculturalism," Toronto Star, 31 August 1991,

(22.) Dewing and Leman, Canadian Multiculturalism, p. 20.

(23.) Keith Spicer, Citizens' Forum on Canada's Future (Ottawa, ON: Minister of Supply and Services Canada, 1991); Brighton Research, Department of Canadian Heritage Corporate Review Branch, Strategic Evaluation of Multiculturalism Program: Final Report (Ottawa: The Branch, 1996).

(24.) Although integration and social cohesion were implicit in the priorities of the multiculturalism policy prior to 1996, after this date they were emphasized more and other priorities were eliminated.

(25.) Dewing and Leman, Canadian Multiculturalism.

(26.) Citizenship and Immigration Canada, Evaluation of the Multiculturalism, 2012,, accessed April 2012.

(27.) Citizenship and Immigration Canada, Application Guidelines for Funding: The Multiculturalism Program 2010, 2010, /funding/guide/101-eng.asp, accessed March 2010.

(28.) Kevin Libin, "This Man Wants to Reinvent Canadian Multiculturalism," National Post, 27 March 2009.

(29.) Jason Kenney, Speaking Notes for the Honourable Jason Kenney, P.C., M.P. Minister of Citizenship, Immigration and Multiculturalism at the Eleventh National Metropolis Conference, Citizenship and Immigration Canada, 2009, /english/department/media/speeches/2009/2009-03-20.asp, accessed January 2011.

(30.) Jason Kenney, On the Value of Canadian Citizenship: Speaking Notes for the Honourable Jason Kenney, P.C., M.P. Minister of Citizenship, Immigration and Multiculturalism, Citizenship and Immigration Canada, 2011, /media/speeches/2011/201 l-12-12.asp, accessed February 2012.

(31.) Joe Friesen, "Jason Kenney: The 'Smiling Buddha' and His Multicultural Charms," Globe and Mail, 2010,, accessed 7 February 2014; Libin, "This Man Wants to Reinvent Canadian Multiculturalism."

(32.) L. Ian Macdonald, "From 905 to 416: The GTA Majority," Policy Options, 2011,, accessed 7 February 2014.

(33.) Region of Peel, Position Statement on Immigration, Peel Regional Government Human Services, 2008,, accessed February 2011; Region of Peel, Diversity and Inclusion Strategy, Peel Regional Government, 2010,, accessed February 2011.

(34.) Peel Newcomer Strategy Group, Newcomer Settlement and Inclusion in Peel: Building on Existing Assets, 2010, /PDF-FILES/Collaborative-Reports/d-1-a-special-report-on-the-vision-of-a-new -model-report-final-june-14-2010.pdf, accessed July 2010.

(35.) Government of the Netherlands, Civic Integration, 2012,, accessed July 2012.

(36.) Rinus Penninx, "Dutch Immigration Policies Before and After the Van Gogh Murder," Journal of International Migration and Integration 7, no. 2 (2006): 241-254; Vasta, "From Ethnic Minorities to Ethnic Majority Policy"; Maria BruquetasCallejo, Blanca Garces-Mascarenas, Rinus Penninx, and Peter Scholten, "Policymaking Related to Immigration and Integration, The Dutch Case," IMISCOE Working Paper No. 15, 2007,, accessed October 2009.

(37.) Netherlands Scientific Council for Government Policy, Immigrant Policy (The Hague: Netherlands Scientific Council for Government Policy, 1990).

(38.) Bruquetas-Callejo et al., "Policymaking Related to Immigration"; Han Entzinger, "Changing the Rules While the Game Is On: From Multiculturalism to Assimilation in the Netherlands," in Michal Bodemann and Gokse Yurdakul, eds., Migration, Citizenship, Ethnos: Incorporation Regimes in Germany, Western Europe and North America (New York: Palgrave Macmillan, 2006), pp. 121-144; Paul Scheffer, "Het multiculturele drama" [Multicultural drama], NRC Handelsblad, 29 January 2000.

(39.) Ian Buruma, Murder in Amsterdam: The Death of Theo van Gogh and the Limits of Tolerance (London: Penguin, 2006). The Lijst Pirn Fortuyn party won 26 out of a total of 150 parliamentary seats in the national elections in May 2002. This was the first election in which this party ran candidates.

(40.) Ministry of Education, Culture and Science, Inhurgeren in Nederland: Wie moet inburgering? 2012, _inburgeren.asp, accessed November 2012.

(41.) The Dutch used the term oldcomers to contrast with the common term for immigrants, newcomers.

(42.) Sheila Kamerman and Dirk Vlasblom, "Muslims Quietly Take Wilders' Abuse," NRC Handelsblad, 24 March 2010. In addition, Geert Wilders was tried in 2010 for inciting hatred and discrimination with his anti-Islamic statements and a film he produced called Fitna, and in 2011 he was acquitted of the charges. John Tyler, "Wilders Trial Coming to an End," Radio Netherlands, 22 June 2011.

(43.) Rudy B. Anderweg and Galen A. Irwin, Government and Politics of the Netherlands (New York: Palgrave Macmillan, 2002); Stephen Mulvey, "Lessons from Coalitions in Working It Out," BBC News, 2010, _depth/8651231.stm, accessed 7 February 2014.

(44.) Gemeente Utrecht, Implementation Program for Diversity and Integration Program 2007-2010 (Utrecht: Gemeente Utrecht, 2008).

(45.) The time limit was three and a half years for newcomers and five years for oldcomers.

(46.) Gemeente Utrecht, Implementation Program.

(47.) Loretta van der Horst, "Battle Brewing over Single-sex Classes for Muslim Women," Radio Netherlands Worldwide. 13 July 2009.

(48.) Ibid.

(49.) Alexandra Xanthaki, "Multiculturalism and International Law Discussing Universal Standards," Human Rights Quarterly 32, no. 1 (2010): 21-48, pp. 22-23.

(50.) Kymlicka, Multicultural Odysseys, p. 88.

(51.) UN Committee on Economic, Social, and Cultural Rights, General Comment No. 21: Right of Everyone to Take Part in Cultural Life, United Nations, 2009, pp. 89,, accessed February 2014.

(52.) Council of Europe, Common Basic Principles for Immigrant Integration Policy in the European Union, Brussels, Council of Europe, Justice and Home Affairs, 2004,, accessed October 2009.

(53.) Ibid., p. 20.

(54.) Council of Europe, Faro Declaration on the Council of Europe's Strategy for Developing Intercultural Dialogue, 2005, Part 1, par. 1, Convention/Source/FARO_DECLARATION_Definitive_Version_EN.pdf, accessed October 2009.

(55.) Ibid., Part 2, par. 1.

(56.) Ibid., p. 10.

(57.) Martha Finnemore and Kathryn Sikkink, "International Norm Dynamics and Political Change," International Organization 52, no. 4 (1998): 887-917.

(58.) Checkel, "Norms, Institutions, and National Identity," p. 86.

(59.) Acharya, Whose Ideas Matter? p. 14.

(60.) Kathleen Burr, "Local Immigration Partnerships: Building Welcoming and Inclusive Communities Through Multi-level Governance," Horizons: Policy Research Initiative, February 2011; Penninx, "Dutch Immigration Policies"; Region of Peel, Position Statement on Immigration, Peel Regional Government Human Services, 2008,, accessed February 2011.

(61.) Susanne Zwingel, "From Intergovernmental Negotiations to (Sub)national Change," International Feminist Journal of Politics 7, no. 3 (2005): 417.

(62.) Maila Stivens, "Introduction: Gender Politics and the Reimagination of Human Rights in the Asia-Pacific," in Anne-Marie Hildson et al., eds., Human Rights and Gender Politics: Asia-Pacific Perspectives (London: Routledge, 2002), pp. 1-36; Brooke A. Ackerly, "Women's Human Rights Activists as Cross-cultural Theorists," International Feminist Journal of Politics 3, no. 3 (2001): 311-346; Zwingel, "From Intergovernmental Negotiations to (Sub)national Change," p. 400.

(63.) Seyla Benhabib, Another Cosmopolitanism (Oxford: Oxford University Press, 2006), p. 48.

(64.) Acharya, Whose Ideas Matter? p. 15.
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Author:Reidel, Laura
Publication:Global Governance
Article Type:Case study
Geographic Code:1CANA
Date:Apr 1, 2015
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