The European Commission wants EU states to consider creating a single procedure for assessing asylum applications, and a single protection status for people allowed into the EU on humanitarian grounds.
By Alix Kroeger
BBC News, Brussels
The suggestion is part of a new discussion paper on the Common European
EU countries agreed to standardise asylum policy at a summit in Tampere, Finland in 1999, but the practice varies widely between EU member states.
For example, the European Council on Refugees and Exiles (ECRE) says Austria grants refugee status to around 90% of claimants from Chechnya, while neighbouring Slovakia accepts almost none.
The green paper says a harmonised protection status "invites reflection on the establishment of a mechanism for the mutual recognition of national asylum decisions and the possibility of transfer of protection responsibilities" between EU member states.
But the "wide margin of discretion" at national level is "negating the desired harmonisation effect."
And it says there are "serious inadequacies" in the way EU countries identify vulnerable asylum seekers. Countries lack the "resources, capacity and expertise" to respond to such needs.
But the idea of a "one-size-fits-all" protection status will be difficult to achieve.
"Member states still do not agree on who qualifies for protection or not," says Kris Pollet of Amnesty International.
"It is very striking: they are all using the same country-of-origin information and yet they all come out with very different results for the same groups. Surely it's an indication that something isn't working."
Organisations working with refugees describe the current system as "a lottery". In an attempt to beat the system, some asylum seekers lodge applications in more than one EU country: so-called "asylum shopping".
Eurodac, which matches fingerprints from across the EU, found that 12% of asylum seekers between 2003 and 2005 had already made a claim in another member state.
Eurodac was set up four years ago as part of the "Dublin system", intended to ensure that asylum seekers have their claim processed in the first EU member state where they declare themselves.
If they make a second claim elsewhere, they're supposed to be sent back to the first country where they applied.
"The Dublin regulation shifts responsibility to states at the edge of Europe," says Richard Williams from the European Council on Refugees and Exiles. "It pits member states against each other."
In the EU, it's the southern countries - Spain, Malta and Italy - which are feeling the strain.
The European Commission paper acknowledges that the Dublin system may create "additional burdens" for frontline states.
Last month, a Maltese skipper refused to pick up 26 African migrants clinging to a tuna net in the Mediterranean because they were in Libyan waters.
The migrants were eventually rescued by an Italian vessel instead.
Last week, a French naval frigate found the bodies of 18 people, thought to be African migrants trying to get to Europe, who had drowned in the Mediterranean.
The Commission green paper says: "Intra-EU resettlement is an important way to pursue", and suggests devising other mechanisms to share the burden more fairly.
But immigration is politically unpopular across the EU, and there's unlikely to be much enthusiasm for taking in migrants who've arrived in another member state.
The total number of asylum applications has been falling for some years. In the 27 countries which now make up the EU, there were 405,455 applications in 2002. That's fallen by more than 50%, to 181,770 last year.
In Britain, the number of asylum applications is at around a quarter of the level five years ago: 103,080 in 2002, down to 27,850 last year.
Around the world, the number of people on the move has never been greater.
The International Organisation for Migration says there are now 192 million people living outside their place of birth, about 3% of the world's population.
The number of migrants is growing by about 2.9% a year.
Increasingly, the Commission green paper says, "member states' asylum systems are seen as forming a single regional protection area. As the external dimension of EU asylum policy grows in importance, greater expectations arise as to the role of the EU."
It also urges EU governments to back ways of stopping would-be asylum seekers from going on the move in the first place: for example, through development aid.
EU governments have sharply different policies on immigration. Formerly liberal countries like Denmark and the Netherlands have tightened up, while Spain is the only EU country to grant large-scale amnesties to illegal immigrants.
So is a common EU asylum policy really possible?
Richard Williams from ECRE argues that the free movement of people, in particular the Schengen area without internal border controls, means there's no choice.
"Once you have a common area of freedom of movement, you have to have common rules and safeguards on who can and cannot come in," he says.