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The politics of immigrant incorporation policies in Korea and Japan.

JAPAN AND SOUTH KOREA (HEREAFTER KOREA), NEITHER OF WHICH ever considered themselves immigrant nations, have encountered a growing foreign population since the early 1990s, a period during which both countries adopted a side-door policy for low-skilled migrant workers in response to the labor shortage experienced by small and medium-sized manufacturing firms. (1) In Japan, the size of the registered foreign population rose from 1,075,317 to 2,134,151 between 1990 and 2010, and the foreign proportion of the population increased from 0.87 percent to 1.67 percent (Immigration Bureau of Japan 2012). During the same period, the size of Korea's registered foreign population climbed from 49,507 to 1,261,415, and the foreign portion of its population increased from 0.11 percent to 2.5 percent (KIS 1990, 2011). More importantly, while Japan and Korea, both known to be culturally and ethnically homogeneous societies, have generally regarded a majority of the foreign population in their countries as temporary sojourners who will eventually return to their home countries, a growing number of foreign residents in the two countries have become permanent settlers, raising crucial policy concerns regarding immigrant incorporation.

In order to address these sociodemographic challenges, Japan and Korea have advanced a series of immigrant incorporation policies, represented by multiculturalism (tabunka in Japanese and damunhwa in Korean). Yet their politics of immigrant incorporation policy have diverged over the past two decades. (2) The Japanese government developed immigrant incorporation policies in the context of the influx of new foreign groups, the so-called newcomers, in the 1990s and 2000s; revisions to the immigration control policy for nikkeijin (or descendants of Japanese emigrants to Latin America) and low-skilled migrant workers from developing countries accelerated this phenomenon. Japan's immigrant incorporation policies have two interesting features worth noting. First, local governments with a large number of foreign residents in their administrative jurisdictions have promoted a wide range of immigrant incorporation policies through cooperation with local civil society organizations, with an emphasis on access to basic services, such as multilingual information, education, housing, and health. Second, although Japan's policymakers focused on alleviating the social and economic insecurity of nikkeijin after the 2008 global financial crisis, the immigrant incorporation policies have not targeted specific foreign population groups.

Korea has also experienced a rapid increase in the size of its foreign population since the early 1990s, in conjunction with the restructuring of Korea's labor-intensive economy and sociodemographic challenges. In contrast to Japan, in Korea it is the central government that has initiated a series of immigrant incorporation policies through a top-down pattern of policymaking. While local governments and local civil society organizations have administered and managed the various immigrant incorporation programs instituted by the central government, few attempts have been made to create immigrant incorporation agendas from the bottom up. In addition, Korea's immigrant incorporation policies, from the entitlement of citizenship to the provision of various support programs, have focused on a specific group within the foreign population--female marriage migrants and children of international marriages--while paying less attention to the rest of the foreign population. (3)

Why have Japan and Korea diverged in their patterns of immigrant incorporation policies, despite many important similarities in immigration control policies and sociodemographic shifts? I argue that a different notion of citizenship for a specific group of foreign residents, created and reinforced by the state, accounts for these variations. To test my claim, I draw from the two countries' parliamentary debates, government documents, policy reports produced by think tanks, quasi-government research institutes, civil society organizations, and interviews as well as the secondary literature.

My article is organized as follows. The first section presents several strands of existing research to explain immigration control and immigrant incorporation policies, focusing on Korea and Japan, and it develops an analytical framework based on the boundary of citizenship. The second section examines Korea's immigration control and immigrant incorporation policies over the past two decades and elaborates on the development of the central government's immigrant incorporation policies that have targeted female marriage migrants and children of international marriages. The third section analyzes Japan's immigration control and immigrant incorporation policies, highlighting the immigrant incorporation policies led by local governments. The conclusion summarizes my main findings and suggests implications for immigrant incorporation policies in the two countries.

Immigration Control and Immigrant Incorporation Policies in Korea and Japan

Although Japan and Korea are considered latecomers to immigration compared to North America and Western Europe, an increasing number of scholars have analyzed each country's immigration control and immigrant incorporation policies. One group of scholars has pointed out that the relationship between the state and civil society accounts for the political process and outcome of immigration control and immigrant incorporation policies (Chung 2010a, 2010b; Lim 2010; Milly 2006, 2014; Shipper 2008; Yamanaka 2010). These scholars argue that Japan's civil society organizations, whose capacity for political and social mobilization is institutionalized at the local level, have contributed to the development of a series of immigration incorporation policies at the local level through cooperation with local governments and officials. (4) In this vein but with a slightly different analytical focus, Haig (2009) claims that strategic decisions made in the early stages of pro-immigrant advocacy efforts between local officials and immigrant advocate groups (especially the migrants themselves, such as zainichi Koreans and nikkeijin) are key factors in explaining variations in immigrant incorporation policies (e.g., in education and housing programs) across different Japanese municipalities. These scholars point out that Korea's civil society organizations for immigrants, most of which developed out of the legacy of nationally organized democratic movements during authoritarian rule, have been more capable of coordinating across different organizations as well as pressuring the central government.

Other scholars emphasize the characteristics of the foreign population as a crucial variable that determines different patterns of immigration control and immigrant incorporation policies, especially at the local level (Flowers 2012; Tegtmeyer Pak 2006). By examining several Japanese municipalities with large foreign populations, they make the claim that the legal status of the municipalities' foreign populations (i.e., documented vs. undocumented foreign populations) and the types of immigrant socioeconomic activities (e.g., low-skilled migrant workers in manufacturing industries vs. foreign workers in entertainment industries) determine the different policy responses of local governments with respect to the foreign populations under their administrative jurisdictions. These scholars have observed that some municipalities experiencing an inflow of newcomers have developed a wide range of immigration incorporation policies that would facilitate the coexistence of Japanese and foreign residents at the local level.

While all these approaches shed light on the politics of immigration control and immigrant incorporation policies in Korea and Japan, I argue that different notions of citizenship for specific groups of the foreign population explain variations in immigrant incorporation policies in the two countries. Chung, who compares the politics of immigrant incorporation in Japan and Korea, claims that "Japan's citizenship-as-identity paradigm" implicitly encourages the status quo for immigrant incorporation, while Korea focuses on the diversification of its monocultural society by implementing various multicultural programs and broadening the boundary of its national identity (Chung 2010a, 657; Chung 2010b, 682-683). Chung also points out that Korea's policymakers have adopted immigrant incorporation policies that would expand the boundary of citizenship to include a specific group of foreign residents, whereas Japan's policymakers have taken more cautious approaches to broadening the boundary of national identity. I take a slightly different approach from Chung by focusing on the mechanism of broadening or restricting the boundary of national identity. In particular, I analyze the ways in which policymakers construct and reinforce the boundary of citizenship (or national identity) for a specific group of foreign residents in Korea based on the principle of family relationships and blood ties. That practice is not followed in Japan.

Citizenship is defined as a form of membership in a political and geographic community, which can be disaggregated into four dimensions of "legal status, rights, political and other forms of participation in society, and a sense of belonging" (Bloemraad, Korteweg, and Yurdakul 2008, 154). The boundary and contents of citizenship have always been redefined and reconfigured in conjunction with social issues pertinent to rights and obligations of citizens, such as immigrants, aboriginal people, and refugees, although scholars have debated the different mechanisms for constructing and identifying the notion of citizenship (Isin and Turner 2002). Some scholars argue that the understanding of nationhood, which was formulated in the process of state building, has shaped the boundary and contents of citizenship (Brubaker 1992). Others claim that variations in institutional regime (such as colonization and partisanship) affect the different processes and outcomes of defining citizenship (Janoski 2010).

Such debates over the boundary and contents of citizenship may apply to Korea and Japan, which follow the principle of citizenship based on jus sanguinis (right of blood) rather than jus soli (right of soil). In addition, the countries' legal procedures for naturalization are not much different from each other. The five-year duration of residence requirement for naturalization in both countries is a good example, although the Korean Nationality Law stipulates Korean language proficiency and an understanding of Korean culture as requirements for naturalization (Seol 2013). (5) As pointed out by Parekh and Kymlicka, cultural or societal communities are based on "collective memories" (Parekh 2000, 162), "territorial concentration and shared languages," and "a sense of belonging" (Kymlicka 1995, 76). Not surprisingly, countries like Japan and Korea, which are well known for being homogeneous societies, are more likely to preserve the purity of their Japanese or Korean national identity, compared to those countries with greater cultural and ethnic diversity.

Despite similarities in their myths of cultural and ethnic homogeneity and the principle of citizenship based on jus sanguinis, the Japanese and Korean governments have developed different approaches to the boundary of citizenship for their foreign populations. Korea has a more flexible and malleable boundary of citizenship for certain foreign residents, while Japan's boundary is more inflexible. Since the mid-2000s, Korea's policymakers have prioritized immigrant incorporation policies that target female marriage migrants and children of international marriages. Compared with other foreign residents, these individuals are considered Koreans, whose political, social, and cultural identity has been formulated by family relationships and blood ties. By offering various immigrant incorporation programs, best exemplified by multicultural programs (e.g., Korean culture and language classes), the government attempts to assist them in acquiring a "true" Korean national identity and thus membership in the Korean family.

Meanwhile, Japan's policymakers have interpreted national identity more rigidly. Scholars have pointed out that Japan's naturalization process places various informal restrictions on foreign residents, hindering them from acquiring citizenship (Chung 2010a, 2010b; Kim 2006; Strausz 2010). Its immigrant incorporation programs, centered on the provision of basic services to local residents, do not aim to educate foreign residents in becoming "true" Japanese. Rather, these programs focus more on defining distinctive boundaries of cultural, ethnic, and national identities along the lines of different foreign resident groups (Kashiwazaki 2009; Nagayoshi 2011). In particular, local governments with a large number of foreign residents within their administrative jurisdictions have promoted various immigrant incorporation programs as a way of enhancing the understanding of different cultures for both Japanese and foreign residents in their communities.

Although I point out that the different boundary of citizenship for a specific group of foreign residents is a key variable for explaining different immigrant incorporation policies in Korea and Japan, I do not argue that immigrant incorporation policies always lead to successful political, social, and cultural incorporation of foreign residents into each society, at either the local or national level. As will be described below, formal citizenship (or legal citizenship) does not guarantee that foreign residents are regarded as true members of political, social, and cultural communities. Therefore, I acknowledge the limitations of immigrant incorporation policy for the improvement of foreign residents' political, social, and economic rights, as well as for changing the attitudes and views held by Korean or Japanese nationals toward foreign residents.

Korea's Immigration Control and Immigrant Incorporation Policies

Korea's Immigration Control Policies for Low-Skilled Migrant Workers

Emulating Japan's Industrial Training Program, which was introduced in 1990, Korea adopted the Industrial and Technical Training Program (ITTP) in 1993. This program allowed labor-intensive small and medium-sized manufacturing firms to hire low-skilled migrant workers from other Asian countries in order to alleviate labor shortages, leading to a rapid increase in the number of these foreign workers under the ITTP (with a D-3 visa for industrial training), from 8,040 to 95,676 between 1993 and 2003 (KIS 1993, 2004). Yet the ITTP, designed to supply a cheap foreign workforce, denied low-skilled migrant workers basic labor rights and social welfare benefits because of their legal status as industrial trainees, not workers. In response to the low-skilled migrant workers' inhumane working and living conditions under the ITTP, Korea's civil society organizations and the Korean Ministry of Labor attempted to reform the ITTP into a guest worker program that would enhance the protection of migrant workers as "workers," not "industrial trainees." Such political efforts did not bear fruit because of the strong opposition of the economic bureaucracy, businesses, and the Korean Ministry of Justice (KMOJ), which worried about extra labor costs for small and medium-sized enterprises (SMEs) and the size of the undocumented foreign population (Kim 2008; Lee and Kim 2011; Lee and Park 2005).

After the center-left Kim Dae-jung government (1998-2002) came to power, Korea began to address the rights and protection of low-skilled migrant workers. Given the presence of a large number of undocumented coethnic workers in the Korean labor market, in 2002 the government introduced the Employment Management System (chiop gwanri jedo) to legalize the employment of ethnic Koreans over forty years old, mostly from China, in the low-skilled service sector. They would be issued a two-year working visa (Skrentny et al. 2007). The succeeding center-left Roh Moo-hyun government (2003-2007) further expanded the hiring of low-skilled coethnic workers by introducing the Working Visit Program (WVP) (bangmun chiop jedo) for ethnic Koreans (over twenty-five years old with foreign citizenship) in 2007. The WVP offered the privileges of labor market access and visa status to coethnic workers (e.g., the H-2 working visa for easy entry and departure from Korea for five years and exclusive employment opportunities in thirty-two sectors).

For other low-skilled migrant workers, Korea introduced the Employment Permit System (EPS) (goyong hogaje) in 2004, which gradually replaced the ITTP. The EPS treated migrant workers as equal to Korean workers by granting them the protection of labor laws and by providing them with basic social welfare benefits. In contrast to the ITTP, whose management was delegated to the Korean Federation for Small and Medium Businesses, the EPS was under the direct control of the government, enhancing the accountability and transparency of Korea's foreign worker policies. Although the EPS does have several remaining problems (such as restrictions on workers' right to change workplaces), the program has contributed to the improvement of the labor and human rights of low-skilled migrant workers in the labor market.

All these important changes in Korea's foreign worker policies took place at the national level, driven by the policy demands of civil society organizations advocating for the rights of migrant workers, as opposed to bottom-up pressure from the local level.

Korea's New Immigrant Groups: Female Marriage Migrants

The underlying assumption of Korea's immigration policy was that low-skilled migrant workers would return to their home countries. Since the early 2000s, however, Korea has confronted the inflow of another group of foreign migrants, namely, marriage migrants (or foreign spouses of Korean nationals), most of whom were foreign brides from Asian and Southeast Asian countries, such as China, the Philippines, Vietnam, and Cambodia. When Korea normalized diplomatic relations with China, local governments and politicians arranged international marriages between Korean bachelors in rural areas and young Korean-Chinese females with the hope of solving the shortage of brides and revitalizing the depopulated local communities.

During the 1990s, the stereotypical image of an international marriage was a family composed of Korean bachelors from rural areas and young Korean-Chinese females. Yet when the Korean government began to deregulate the marriage service industry by changing the license system to a registration system in 1999, new trends in international marriage emerged. First, the number of marriage service agencies and international marriages increased dramatically. As of 2012, there were 1,423 registered marriage service agencies, a near doubling of the approximately 700 agencies in 1998 (Donga-Ilbo 2013; Kim and Kim 2010). In addition, the number of marriage migrants increased from 44,416 to 144,214 between 2003 and 2012, a majority of whom were females (86.4 percent as of 2011), and the proportion of international marriages climbed from 1.2 percent to 10.5 percent between 1991 and 2010 (KIS 2007, 2011; Korean Statistical Office n.d.; KWDI 2011). Second, the origins of marriage migrants expanded from the Korean diaspora in China and the Han Chinese in the 1990s to those from Southeast Asia in the 2000s (Lee 2008). Finally, although the first phase of international marriage was concentrated in rural areas, international marriages have been growing rapidly among low-income urban Korean males since the mid-2000s. More than half of international marriage couples (54.3 percent as of 2011) now live in the urban areas of Seoul, Incheon, and Gyeong-gi province (KIS 2011).

The growing number of marriage migrants and children of international marriages has imposed new policy concerns for the government. Unlike low-skilled migrant workers, most of whom were expected to return to their home countries, marriage migrants and children of international marriages have been regarded as permanent settlers as well as members of Korea's political, social, and cultural community, based on their family relationships and blood ties with Korean nationals. In addition, the nation's policymakers considered female marriage migrants a critical policy solution for perceived population problems, such as declining fertility rates, an aging society, and depopulation in rural areas, since these marriage migrants would give birth to babies and provide unpaid care for elderly in-laws (Lee 2008; Michel and Peng 2012; Yoon 2008). The Korean government thus prioritized immigrant incorporation programs for this specific group of foreign residents as a population policy.

Korea's Immigrant Incorporation Policies

In the face of the inflow of marriage migrants in the early 2000s, Korea's policymakers began to focus on immigrant incorporation policies. The Roh Moo-hyun government announced a policy direction of comprehensive immigrant incorporation policies, which it identified as multiculturalism (Lee 2008). In April 2006, the Roh government proposed to provide a wide range of government policy support for mixed-race people, immigrants, marriage migrants, and children of international marriages (Kim et al. 2012). (6) Based on the policy principle of multiculturalism, two important pieces of legislation were enacted: the 2007 Framework Act on Treatment of Foreigners Residing in the Republic of Korea (jaehan oigukin chowu gibonbop, hereafter Framework Act), which aimed to improve the social and economic rights of foreign residents), and the 2008 Multicultural Families Support Act (damunhwa gajok jiwon bop), which aimed to assist marriage migrants and children of international marriages in settling into Korean society.

When the National Assembly began to discuss the Multicultural Families Support Act in 2007, the justice ministry strongly opposed the legislation by arguing that the Framework Act, which is under the ministry's administrative jurisdiction, was capable of covering marriage migrants and children of international marriages (Parliamentary Debates 2007a). Some conservative politicians were also reluctant to pass the Multicultural Families Support Act, since they considered such a specific legislation unnecessary, given the presence of the immigration control system for foreigners (Parliamentary Debates 2007a).

Meanwhile, the Korean Ministry of Gender Equality and Family (KMOGEF), to whom the government assigned the role of central coordinator of multiculturalism, argued for the necessity of passing this legislation. The ministry strongly asserted that the government should provide well-designed policy support programs for marriage migrants and children of international marriages corresponding to the life-course cycle of these population groups, including prenatal care, maternal health care, child rearing, and education of children in the public school system. In particular, the KMOGEF pointed out that international marriages would continue to increase and that marriage migrants and their children should be regarded as Korean citizens based on their family relationships with Korean nationals (Parliamentary Debates 2007b, 2007c). In addition, the ministry argued that the Multicultural Families Support Act would be critical for marriage migrants who decided to become naturalized citizens of Korea, by pointing out the crucial policy loophole in the Framework Act, namely, that the act's coverage for naturalized citizens was for only three years (Parliamentary Debates 2007c). After several rounds of debates at the National Assembly, the Multicultural Families Support Act finally passed in March 2008. Support came from both the ruling and opposition parties, which agreed on the need to confront the pressure of sociodemographic challenges and the necessity of assisting marriage migrants and their children in becoming members of Korea's cultural, social, and political community.

While a series of immigrant incorporation policies attempted to include marriage migrants and children of international marriages within the boundary of Korean citizenship, they also raised several crucial concerns and sparked new debates over Korea's immigration incorporation. First, the definition of the multicultural family--the core element of Korea's immigrant incorporation--was very narrowly defined. According to the original legislation of the Multicultural Families Support Act, a multicultural family was defined as being composed of a Korean citizen (who had acquired Korean citizenship at birth) and a foreign spouse. This legal definition excluded families composed only of foreign nationals, or families composed of naturalized Korean citizens and their foreign spouses. In response to such critiques, the legal definition of the multicultural family was slightly modified. Since September 2011, the boundary has been extended to include families composed of a naturalized Korean citizen and a foreign spouse (National Library of Korea n.d.).

Second, although the government recognizes a family composed of a female Korean citizen and her male foreign spouse as a multicultural family, a majority of multicultural family support programs exclusively focus on helping female marriage migrants become Korean citizens, which is indicative of the patriarchal Korean society. Korea's immigrant incorporation policies prioritize the question of how to help female marriage migrants become true Korean citizens, as well as how to become a "good wife and wise mother," by offering various multicultural family support programs. These include Korean language classes, Korean culture and cooking lessons, family counseling services for marriage migrants, prenatal and maternal health programs, and other social events in local communities (J.-S. Kim 2011; KMOGEF 2012; Yoon 2008).

Lastly, while the government increased the budget for multicultural policies, from 12 billion won in 2006 to 887 billion won in 2011, more than two-thirds (71 percent) of the budget was allocated for marriage migrants and children of international marriages. Meanwhile, the budget for programs for low-skilled migrant workers and their families dwindled, although these individuals comprised a significant majority (around 80 percent) of Korea's foreign population (Joo 2010; KMOGEF 2012). Other government policy support programs also targeted marriage migrants and children of international marriages--for example, the revision of the Basic Livelihood Security Law to cover marriage migrants with underage children who are Korean citizens or a lineal ascendant--implying that the status of marriage migrants can be acknowledged only as part of a family as opposed to the individual (Korean Ministry of Government Legislation n.d.). Korea's immigrant incorporation policies were based on the principle of the patriarchal family system and cultural paternalism, as opposed to emphasizing the equally important value of cultural diversity (J. Kim 2011; Kim et al. 2012).

The role of local governments and local civil society organizations has been one of the major differences in Korea's immigrant incorporation policies compared to Japan's. In Korea, a large number of multicultural programs have been delegated or contracted out to local governments and local civil society organizations, since the central government has been unable to manage all the programs (Yoon 2008). Most local governments, even those with large foreign-born populations, have been following the policy principles and guidelines of the central government, as opposed to promoting their own innovative immigrant incorporation policies at the local level. (7) The role of civil society organizations has also become rather secondary in regard to the development of multicultural programs. A large number of them have been less capable of proposing bottom-up policy changes. They have also lacked a stable supply of resources to support their activities and organizations, leading to heavy reliance on the government's financial support as well as a close working relation ship with the local and/or central government (Cho and Park 2012; Yang et al. 2010). Most local activities of nongovernmental organizations have been based on local government project contracts (71 percent), although a small percentage of their activities are based on consulting (17 percent) and joint projects with local governments (5 percent) (Chung et al. 2012). The weak political and organizational capacities of both local governments and local civil society organizations in relation to immigrant incorporation policies may be traced to Korea's relatively short history of local autonomy (resuming only in 1995 after a three-and-a-half-decade interruption that followed the 1961 military coup) and more nationally centered civil society organizations.

Korea's immigration incorporation has been driven by the central government in the context of defining the boundary of citizenship at the national level (as opposed to the provision of basic services to all foreign residents), and its immigration incorporation policies have specific targets (i.e., marriage migrants and children of international marriages). Debate has grown over whether the government needs to further extend immigrant incorporation strategies to the rest of the foreign population, beyond female marriage migrants and children of international marriages. In fact, according to the second Basic Plan on Immigrants, the Korean government emphasizes the expansion of immigrant incorporation policies toward a wide range of migrants and not simply marriage migrants (Korean Committee on Immigrants 2013). The next step should be to examine the extent to which Korea's immigrant incorporation policies have influenced understanding held by Korean nationals and changed their attitudes toward foreign residents.

Japan's Immigration Control and Immigrant Incorporation Policies

Changes in Japan's Immigration Control Policies

Japan already had a substantial number of foreign residents--zainichi Koreans--as a result of its colonialism: 598,507 in 1947, which accounted for 93.6 percent of registered foreign aliens (Kim 2006). Yet Japan did not develop comprehensive immigrant incorporation policies for foreign residents until the early 1990s, aside from a few local political attempts to incorporate zainichi Koreans into local communities. In 1990, in response to labor shortage problems in production lines, the Japanese government revised the Immigration Control and Refugee Recognition Act to entitle nikkeijin to long-term resident status with no restrictions on job categories (Oishi 2005; Yamanaka 1993). By implementing a de facto guest worker policy for nikkeijin, Japan's policymakers expected that these migrant workers would alleviate the labor shortages without disrupting Japan's ethnic homogeneity (Skrentny et al. 2007). The number of nikkeijin coming from Brazil increased dramatically from 56,429 in 1990 to 210,032 in 2011, and peaked at 316,969 in 2007, just one year before the 2008 global financial crisis that led to the return of a large number of nikkeijin to Brazil (Immigration Bureau of Japan 2012).

In addition, the Japanese government modified the Industrial Trainee Program in 1990. Originally established in 1982, the program was intended only for companies with capital and trade relations with foreign counterparts with more than twenty employees, in order to allow mostly small and medium-sized enterprises to hire low-skilled migrant workers as industrial trainees from China and Southeast Asian countries (Immigration Bureau of Japan 2012; Vogt 2010). The problem of bride shortages in rural areas (such as Yamagata, Iwate, Niigata, Tokushima, and Nagano Prefectures) led to an increase in international marriage in Japan beginning in the mid-1980s (Satake 2011b; Suzuki 2003). (8) Yet the proportion of international marriage in Japan was much smaller than in Korea; Japan's international marriages accounted for only 4.9 percent of the total marriages in 2009, a figure that had increased from 0.5 percent in 1970. (9)

Japan's Immigrant Incorporation Policies

The rapid increase in the number of newcomers since the early 1990s has raised important concerns for Japan's policymakers. First, although the Japanese government had regarded the foreign residents as temporary sojourners, a growing number of nikkeijin, who were allowed long-term stays based on their visa privileges, began to settle down in municipalities in the Tokai region (e.g., Hamamatsu and Toyota) where a majority of small and medium-sized labor-intensive manufacturing firms are concentrated. Second, despite their different ethnic identity as Koreans, zainichi Koreans (especially young zainichi Koreans who were born and raised in Japan) have been culturally integrated into the Japanese society (Kashiwazaki 2009, 124). By contrast, the so-called newcomers, most of whom arrived in Japan since the 1990s, were culturally and ethnically different, although Japan's policymakers had initially believed in the myth of nikkeijin ethnic homogeneity (Haig 2009; Skrentny et al. 2007).

In the face of the increasing number of foreigners residing in Japan, the concept of multiculturalism was endorsed during the 1990s and 2000s by local governments with a large number of "old comers" (mostly zainichi Koreans) as well as newcomers in their administrative jurisdictions, such as Osaka, Hamamatsu, and Kawasaki. In 1996, Kawasaki City, which has been well known for a large number of both groups, organized the Council on the Representation of Foreign Residents (gaikokujin shimin daihyosha kaigi) in order to incorporate the voice of foreign residents in local policymaking (Han 2004; Satake 2011a). Emulating the model of Kawasaki City, several other municipalities with large foreign populations also established various consultative bodies composed of foreign residents in the 1990s (Tegtmeyer Pak 2006). In 2001, thirteen municipalities with a large number of foreign residents established the Council of Cities with High Concentrations of Foreign Residents (gaikokujin shujutoshi kaigi) in order to coordinate policy demands of local governments for immigration control and immigrant incorporation policies at the national level. As of 2009, the number of municipalities that joined the council had increased to twenty-eight, and nineteen of these twenty-eight municipalities were located in Aichi, Mie, Kifu, and Shizuoka Prefectures, where a large number of small and medium-sized labor-intensive manufacturing firms are located (Haig 2009; Satake 2011a).

In addition, since the 1990s the Council of Local Authorities for International Relations (jichitai kokusaika kyokai or CLAIR), which has been affiliated with the Japanese Ministry of Internal Affairs and Communications (JMIC), has shifted its policy focus from promoting the internationalization of local governments to advocating for multiculturalism (CLAIR n.d.). By participating in CLAIR, local governments have effectively pressured the central government to develop more comprehensive immigrant incorporation programs at the national level (Interview 2013a). The Japan Intercultural Academy of Municipalities (jenkoku shichoson kokusai bunka kenshusho or JIAM) has also offered various training programs for local officials, whose programs have emphasized not only intercultural diversity but also cultural cohesion (Interview 2013b).

The central government's slow response to the inflow of foreign residents contrasts sharply with local governments' policy initiatives for foreign residents. Pressured by the bottom-up demands of these local governments with a large foreign population, in 2006 the JMIC announced the principle of multicultural coexistence (tabunka kyosei), which was Japan's first comprehensive policy framework for immigration incorporation at the national level (Chung 2010b). The JMIC's report suggested that the central government request local governments to set multiculturalism and coexistence as key pieces of their policy agenda, with a specific emphasis on three issue areas relevant for foreign residents in local communities: support for communication, support for living, and multicultural coexistence with the local community (JMIC 2006).

While the central government acknowledged the importance of the legal framework at the national level, it regarded immigrant incorporation as a very locally centered goal, whose political agenda had in fact already been promoted at the local level (JMIC 2006). Since 2006, Aichi, Gifu, and Gunma Prefectures have created guiding principles for implementing the idea of multicultural coexistence and providing basic social services for foreign residents (Tai 2009). In addition, governors and other local politicians whose communities have a large number of foreign residents have initiated a series of immigrant incorporation policies at the local level, such as the provision of multilingual information, education, housing, and health programs (Interview 2013c).

By focusing on immigrants as local residents in communities, as opposed to citizens at the national level, Japan has addressed the increasing number of foreign residents without extending the boundary of citizenship to them. It has made few attempts to incorporate Japanese returnees from China into Japanese society or to entitle a foreigner raising a child whose parents are a Japanese citizen and a foreign national to remain in Japan (Milly 2014). Nevertheless, the boundary of citizenship has not been far extended to foreign populations in Japan, which have been constrained by the legal framework of immigration control already institutionalized in response to zainichi Koreans in the postwar period.

At the national level, in response to the central government's proposed multicultural coexistence, some Diet members whose electoral constituencies have a significant number of foreign residents have become interested in immigrant incorporation policies (Interview 2013a; Milly 2014). Yet a majority of immigrant incorporation policies have been advanced by policy initiatives of local governments and local civil society organizations to cope with the growing number of foreign residents in their municipalities (Interview 2013a). Japan's decentralized policymaking in the realm of immigrant incorporation is thus distinctive compared to Korea's centralized mode. Stronger local autonomy in Japan, institutionalized in the process of its prewar and postwar political development, compares with Korea's shorter history of local autonomy.

Also in contrast to its Korean counterpart, the Japanese government has not targeted any particular group for the eligibility and benefits of immigrant incorporation programs. While the Committee on International Relations (kokusai koryukai) at the local level has initiated several programs to support the settling of female marriage migrants in local communities, neither the central government nor the local governments have proposed any specific immigrant incorporation programs for marriage migrants and children of international marriages (Interview 2013b). Following the 2008 financial crisis, the Japanese government developed a wide array of programs to assist nikkeijin in finding new jobs during severe economic downturns, including Japanese language programs, public works projects, foreign language services for local administration, and job training programs (Japanese Cabinet Office 2010).

Despite the use of the term multicultural coexistence, Japan has restricted the boundary of national identity to include only citizens who acquired Japanese nationality at birth, thus excluding foreign residents. In Japan, the formal and substantive notions of citizenship also have been restrictive even for marriage migrants; compared with Korea, a substantial number of marriage migrants in Japan have not become naturalized Japanese citizens, despite similarities in the simplified process of naturalization for marriage migrants and its legal requirements in the two countries. While Japan's central government has taken rather cautious approaches to immigrant incorporation, its local officials and governments have incorporated them into their municipalities as local residents without prioritizing any specific foreign group in their immigrant incorporation policies (Chung 2010a, 2010b; Haig 2009; Kim 2006; Milly 2006; Strausz 2010; Tegtmeyer Pak 2006).


In the face of economic and sociodemographic challenges, Japan and Korea, long known for being culturally and ethnically homogeneous societies, confronted an influx of foreign-born residents beginning in the early 1990s, raising a policy concern about immigrant incorporation in both countries. As the existing literature on immigration and immigrant incorporation in Japan and Korea highlights, the relationship between the state and civil society organizations, and the characteristics of the foreign population, are crucial factors in how governments develop patterns of immigration and immigrant incorporation policies. Although I do not discount the importance of these factors in explaining the politics of immigration and immigrant incorporation policies, I argue that the differing boundaries of citizenship should be taken into account in explaining the diverging pathways of immigrant incorporation policies in Japan and Korea over the past two decades. In Korea, the central government has attempted to incorporate female marriage migrants and children of international marriages into its cultural and social communities through the entitlement of citizenship and the provision of various policy programs in order to assist them in becoming true Koreans. Meanwhile, other groups of foreign residents have been mostly excluded from the benefits and eligibilities of immigrant incorporation policies at the local and national levels, regardless of the length of their stay. In Japan, its legacy of immigration control for zainichi Koreans seems to restrict the scope of policymaking at the national level with respect to the entitlement of citizenship, while allowing local governments and local civil society organizations to have leeway to develop various immigrant incorporation programs and help foreign residents settle in their local communities.

Despite very similar characteristics of restrictive immigration control policies in the two countries, Korea and Japan have developed different notions of citizenship, whose boundaries have been created and reinforced by the state, and advanced different sets of immigrant incorporation policies. The remaining issue in this regard is the extent to which a series of immigrant incorporation policies can enable foreign residents to be fully incorporated into Japanese or Korean society as members of political, cultural, and social communities.


Jiyeoun Song is assistant professor of international studies in the Graduate School of International Studies at Seoul National University. Her research lies at the intersection of comparative social policy and comparative political economy, with a regional focus on East Asia. She is author of Inequality in the Workplace: Labor Market Reform in Japan and Korea (2014). She can be reached at This article was supported by the Research Resettlement Fund for the New Faculty of Seoul National University, grant number 870-20140012.

(1.) A side-door policy refers to Japan's Industrial Training Program (1990) and Korea's Industrial Technical Training Program (1993), which allowed Japanese and Korean small and medium-sized enterprises to hire foreign industrial trainees based on fixed-term contracts (usually two or three years) in order to cope with labor shortages in their production sites.

(2.) While multiculturalism refers to the recognition of a wide range of minority rights (e.g., gender, ethnicity, language, race, and religion) in the West, multiculturalism in Japan and Korea is usually identified as immigrant incorporation by emphasizing the relationship between nationals and foreign residents in their societies. Regarding an overview of multiculturalism in Asia, see He and Kymlicka (2005).

(3.) To clarify, children of international marriages with a Korean father or mother are granted Korean citizenship.

(4.) Examining the characteristics of Japan's civil society, Pekkanen (2006) has proposed the term dual civil society, which refers to the development of many small local civil society organizations but few large professionally managed groups at the national level. This difference is responsible for the limited influence of the nation's civil society organizations on policy debates and policymaking at the national level.

(5.) In Korea, foreigners with a Korean mother or father need to fulfill the three-year duration of residency requirement and marriage migrants need to fulfill a two-year requirement (Korean Ministry of Government Legislation n.d.).

(6.) Regarding the background of this policy change, see Lim (2010). The Roh government's grand plan emphasized the governance role of local governments and local civil society organizations rather than the central government for support of foreigners (Milly 2014). Yet Korea's immigrant incorporation has been led by the central government.

(7.) Emulating their Japanese counterparts, in November 2012 twenty-four cities with a large number of foreign residents formed the Organization for the Multicultural City (jonguk damunhwa doshi hyouihoe) in order to coordinate the political positions of local governments regarding immigrant incorporation (Chung et al. 2012). Yet this organization has not been very active compared with its Japanese counterpart.

(8.) One thing to note is that marriages between Japanese nationals and zainichi Koreans (those with South Korean, North Korean, or Chosun citizenship) were also counted as international marriages in the government statistics. In 1990, 45.5 percent of international marriages in Japan were those between Japanese nationals and Korean spouses. But the statistical data make no clear distinction between zainichi Koreans and other types of Koreans. The percentage of international marriage between Japanese nationals and Koreans declined to 17.4 percent in 2009, while the number of foreign spouses from China, the Philippines, and Thailand increased drastically during the 2000s (Japanese Ministry of Health, Labor, and Welfare n.d.).

(9.) For details, see the home page of the Japanese Ministry of Health, Labor, and Welfare (n.d.).


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