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This paper aims at providing a general picture of how the citizenship migration nexus currently unfolds in China and in the European Union (EU). Although China is a nation state and the EU is a supranational entity, both entities are characterised by internal and external politico-legal borders delineating two self-contained migration areas. Drawing on a definition of citizenship which transcends its usual national connotation, this paper will review and compare how different migration categories available to individuals on the move (citizens and non-citizens) come with differential accesses to citizenship rights within the two contexts. The comparison will show that in spite of different approaches towards irregular migration, welfare and humanitarian issues, current categories of migration within these two migration regimes converge in the way in which they grant differential access to citizenship rights based on the (assumed) economic worth of individuals on the move. The final part of this paper reflects upon the lessons that each system could draw from the other and postulates such convergence as an indicator of the correlation between the granting of citizenship rights and neoliberal imperatives in the governance of migration worldwide.

Migration regimes and the governance of citizenship: a comparison between legal categories of migration in China and in the European Union