Comparing the development of free movement and social citizenship for internal migrants in the European Union and China - converging trends?

Even though the European Union (EU) and China are different types of political units, this article explains why they can be compared in a meaningful way as internal migration areas. National citizenship of an EU member state is compared to hukou status in China, as both constitute relevant affiliations to geopolitical units with decisive implications for social citizenship. The development of social citizenship with regard to these affiliations is described. A periodization of developments in relation to legal affiliation and social rights since the 1950s is suggested showing that there are converging trends between the EU and China. Nowadays, the EU and China are areas of virtually free movement. However, the EU is far ahead concerning the social rights of internal migrants, while China has only recently started putting efforts in this direction. As a result, internal migrants in the EU are much better protected against the loss of social rights when leaving their country of national citizenship than Chinese migrants who leave their hukou region. The issue of whether free movement and more accessible social rights for migrants represent a step on the road towards a full set of civil and political entitlements of citizenship is reflected in the conclusions.