The German state of Baden-Wuerttemberg has given initial approval for a law to stop teachers wearing headscarves.
Teacher Fereshta Ludin's court prompted states to legislate
The draft law, which has been proposed by centre-right parties, has passed its first reading and will return for final approval at the end of March.
The education ministry wants to ban any public show of religion or politics which could jeopardise the neutrality of the state education system.
France is also debating whether to ban any overt religious symbols in schools.
Seven other German states, including Bavaria, are expected to propose similar laws to the Baden-Wuerttemberg plans in the near future.
The proposals follow a controversial ruling by Germany's highest court in September last year that states were entitled to ban teachers from wearing headscarves.
Thirty-one-year-old Fereshta Ludin, who was denied a job in Baden-Wuerttemberg in 1998 because she wore a headscarf in school, went to court arguing that the German constitution guaranteed her religious freedom.
The federal Constitutional Court ruled by five votes to three that, under current laws, she could wear the scarf. But it also said new laws could be passed by individual states.
Civil rights organisations and groups representing the 3.2 million Muslims living in Germany have strongly criticised the proposed ban.
They argue that the right to wear a headscarf is a question of religious freedom.
The French proposals, which have the backing of President Jacques Chirac, would lead to a schools ban on religious symbols such as Islamic headscarves, Jewish skullcaps and large crucifixes or crosses.
A vote in the French National Assembly is expected next Tuesday.
Christian and Jewish symbols are not included in the Bavarian plans for a ban.