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Page last updated at 17:30 GMT, Tuesday, 21 October 2008 18:30 UK

Should UK immigration go Dutch?

Ethnic Moroccans in Slotervaart neighbourhood, Amsterdam
Ethnic Moroccans form a large minority in the Netherlands

Are the Dutch handling immigration more efficiently than the British? UK Immigration Minister Phil Woolas thinks so - he has condemned the UK's migration limits and asylum policy and praised Dutch measures.

Here BBC News reporters Dominic Casciani and Laurence Peter look at the UK and Dutch systems, respectively.

UK SYSTEM

The UK's immigration system has faced massive upheavals and change over the past decade - and it remains a touchy subject on voters' doorsteps.

The old migration system was basically a mess - and an open invitation to abuse, chaos, haphazard decision-making and unfair treatment.

There were too many entry routes, no proper system for counting who came and went - and no guaranteed means of working out what happened to people who stayed.

What made matters politically far worse for the government was the huge surge in asylum applications in the late 1990s.

So it came as little surprise when the former UK Home Secretary, John Reid, described the system in 2006 as "not fit for purpose", after officials released 1,000 foreign prisoners without considering them for deportation.

But from those low points, ministers argue that changes in three key areas are bringing benefits:

  • Economic immigration for workers
  • Access for asylum seekers and refugees
  • Settlement, nationality and citizenship.

The multiple entry routes for workers are being progressively replaced with a simpler system.

If you are a worker from within the European free market area, you can come and go as you please. If you are from anywhere else, you must score points to come in under one of a number of categories - a successful system used in Australia among other countries.

Rules have been increasingly tightened for asylum seekers, spouses or dependents. Spouses will soon be expected to sign up to English lessons as a condition of settlement. The minimum age for someone coming into the UK to wed is also being raised to 21, partly to combat forced marriages of vulnerable women.

Critics say the asylum system has gone from chaotic to unfair because of the high rate of rejections.

Supporters say it has simply exposed the high number of bogus applications. The new immigration minister concedes that rejected asylum seekers, who cannot work, have been destitute in the UK because of a failure to ensure they are deported in a timely fashion.

Ministers hope to underpin these reforms in two ways. The first is practical - the UK's borders are going electronic with ID cards, biometric applications and checks at airports as people come or go.

The second element is about shifting perceptions and creating a sense belonging. The Home Office plans to use a carrot-and-stick approach to ensure migrants go on a "journey towards citizenship". They will have a choice to "earn citizenship" over a minimum of six years - or to go home.

Critics say it is daft and insulting to people who work hard in jobs that the British often do not want to do.

But ministers think it is a good social contract that can help to ease the tensions that have built up over immigration.

Public citizenship ceremonies have been taking place for some years now - and they were criticised as a bit silly and American. But for more migrants, they are an important moment, with barely a dry eye in the house.

DUTCH SYSTEM

Dutch immigration policy has shifted markedly away from multiculturalism and towards promoting integration and Dutch identity.

The new rules for non-EU citizens contrast sharply with the liberal policy of the 1960s and early 1970s, which enabled many Moroccans and Turks to settle easily in the Netherlands as "guest workers", brought over to fill jobs in heavy industry.

In March 2006 the Netherlands introduced a Civic Integration Examination for would-be permanent migrants, requiring them to take courses in the Dutch language and "social orientation". The latter includes scenes of nudity and homosexuality in a controversial video on Dutch liberal values.

The examination can be taken at a Dutch embassy and has to be passed before the applicant can settle in the Netherlands. Spouses wishing to join a partner in the Netherlands have to take it, regardless of how long the partner has been a Dutch resident.

But a court in Roermond overruled a condition which said the spouse's partner had to be earning at least 120% of the minimum wage for them to live together in the Netherlands.

Permanent resident status depends on the migrant completing an integration programme, which involves more language tests and active engagement with wider Dutch society, for example through an internship or volunteer work.

The programme lasts three-and-a-half years, but for asylum seekers and previously settled migrants it is five years. Spiritual leaders such as imams, whose visas are limited to three years, also have to take the integration course.

Pressure to tighten the rules came especially from the popular politician Pim Fortuyn, who took the political establishment by storm in 2002, tapping into widespread concern about growing numbers of poor migrants who spoke little or no Dutch.

Attention focused on the marginalisation of young Muslims when in November 2004 the film-maker Theo van Gogh was murdered by a young Dutchman of Moroccan origin. Van Gogh had made a film about domestic abuse of Muslim women.

Migrants from outside the EU are particularly concentrated in Dutch cities, notably Amsterdam and Rotterdam, which was Pim Fortuyn's political stronghold. Morocco and Turkey are the main countries of origin by far. A Dutch-Moroccan pro-integration politician, Ahmed Aboutaleb, is poised to become mayor of Rotterdam.

Compulsory naturalisation ceremonies also feature in the new rules for would-be residents.

In 2006, immigrants formed 19% of the Netherlands' 16.3 million people. The unemployment rate among them was 12.2% - a full 8.5% higher than the rate for Dutch nationals.

Family reunifications account for much of the increase in the immigrant population since the 1970s, according to Peter van Krieken, professor of international law at Webster University, Leiden. There was no obligation for these spouses to learn Dutch. He recalls a time when in town halls "you used to see lots of signs in other languages and a court would say 'you can't force people to learn Dutch'."

The Netherlands does not have a big backlog of asylum seekers to process, unlike the UK.

Asylum cases have been accelerated through a 48-hour procedure, so that hopeless claims can be eliminated quickly. The number of asylum applications in 2007 was nearly 10,000, with Iraqis and Somalis forming the largest number.

Dutch procedures for illegal immigrants have also been accelerated, with cases now coming under employment law, rather than the penal code. Access to jobs has been targeted, rather than putting the emphasis on deportations. Inspections of work premises are more frequent now and "within 10 days employers can be served with a big fine," Prof Van Krieken says.



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