ABSTRACT
In discussions of citizenship law and models of national membership, Germany and France have often been contrasted as representing opposite ends of the spectrum with profoundly different and historically entrenched traditions of national belonging. 1 The German system is traditionally cited as typifying the 'ethnic nation' where membership is defined along principles of descent and notions of inherent and homogeneous 'Germanness'. France, on the other hand, is thought to exemplify the 'civic nation' where membership is based on shared political allegiance and acquired cultural knowledge. Newcomers to Germany without provable connections to German bloodlines have by and large remained perpetual outsiders, regardless of their degree of cultural fluency or length of residence in Germany, whereas new arrivals in France have encountered fairly permeable borders and at least legally been incorporated into the nation. Becoming 'French' has long been an encouraged and expected transformation; becoming 'German' has until very recently been a logistically formidable process and ideologically difficult to imagine.2
