THE CASE OF FREE
MOVEMENT
FOR WORKERS
BETWEEN
TURKEY
AND THE EUROPEAN
UNION
BERDAL ARAL
ı.
The Regulation on Free Movement for Workers Under the Turkey-EC LawTurkey has be en an associate member of the EV sinee i963. The Ankara Agreement of 19631 regulates cconomie, social and financial mallers. In the preamble, it is stated that the agreement seeks to bring about 'ever closer bonds between the Turkish pcople and the pcople brought together in the European Economic Community'. It was believed that social and cultural integration between their people could best be achieved through the movement of peoplcs across national boundaries. This, the parties sought to achieve through the gradual introduction of 'freedom of movement for workers, professionals and entrepreneurs' (Articles 12 to 14 of the Ankara Agreement) Since the international mavement of labour involves far greater number of individuals, it is this aspect of social integration whieh deserves particular attention.
It is clcar that, from the outset, Turkey saw the Ankara Agreement as a means, among other economic and politieal goals, to improve the legal status of Turkish migrant workers in Western Europe, most of whom had laken up employment in the EC countries. By the time when, for instance, the Additional Protocal cam e into foree in 1973, the number of Turkish workers in West Germany alone had risen from 7,000 in 1961 to well over
1Association Agreement Between Turkey-EEC, 12 September 1963 (OJ EC No. 113/2, 24.12.1973)
2 THE TURKISH YEARBOOK [VOL. XXVIL
600,000.2 Indecd the principle of frec movement was one of the comerstones of the association in view of the tasks which Turkey had to carry out during the transitjonal stage. Today some 1 million Turkish workers are employcd in the EU countries, of whom 700,000 rcside in Germany. Together with their families, they make up one of the largest migrant communities in the EU with a population of nearly 3 millions.
The Ankara Agreement was a programmatic document composed mainly of a set of guidelines that would govem the relations betwcen Turkey and the Communily in the transitional and final stages. This was also the case with Artiele 12 of the Ankara Agrecment, which declared that the Parties were agrecd 'to be guided by Artides 48, 49 and 50 of the Treaty establishing the Community for the purpose of progressively securing freedom of movement for workers between thern.' The said artieles of the Treaty of Rome provided the legal framework for the gradual establishment of frecdom of movement for the workers within the Community. Through the adoption of various directives and regulations within the spccified time scale -12 years, in accordance with Artiele 48, workers belonging to a member of the Community began to enjoy the right to migraıe, to reside and to work in the EC countries other than their own: to bring in their family membcrs, and to enjoy equal employment conditions and social advantages.3 In the light of the linkage between Artiele 12 of the Ankara Agrccment and the relevant artieles of the Treaty of Rome, one could reasonably expect similar arrangements to be made for the labour circulation between Turkeyand the EC countries during the transitional stage.
An Additional Protocol to the Ankara Agrecmenf was signed betwccn the Parties in 1970 (came into force in 1973) to coordinate the transitional stage. Artiele 36 of the Protocol stipulated that free movement of workers between Turkeyand the Community was to be achieved on a progressive basis during the period betwcen 1 Dccembcr 1976-1 December 1986. Under the second paragraph of the same Artide, it was statcd that 'the Council of Association shall decide on the rules to that end'. On the basis of Artiele 36, the Community was under an obligation to remove the migration barriers against Turkish workers, while guaranteeing equal treatment for Turkish workers aıready resident in the EC member states. To Turkey's disappointment, however, the implementation of this basic principle has not
2Nermin Abadan Unat and Contributers, Turkish Workers In Europe: 1960-1975, Leiden: E. J. Brill, 1976.
30errick Wyatt and Alan Oashwood, The Substantive Law of the EEC, second edition, London: Sweet & Maxwell, 1987, pp. 165-186.
4 Addltlonal Protocol to the Assoclation Agreement, 23 November 1970, (OJ EC No. C 113/17, 24.12.1973)
1997J THE CASE OF FREE MOVEMENT FOR WORKERS 3
yet been defincd due mainly to the labour market eonsiderations of the EC Member States.
As is weB known, the economic recession which prevailcd in the aftermath of the oil crisis of 1973-74 resultcd in high unemployment rates in countries of Westem Europe. This gaye the Community the pretext to set aside any possibility of introducing freedom of movement for Turkish workers. The Community refused to introduce free movement even for Turkish workers aıready settled in the Community. The Council of Association, established by the Ankara Agreement as the main decision-making body to ensure the proper functioning of the assoeiation, has thus far adopted two dccisions -in 1976 and 1980- which were supposed to pave the way for a complcte introduction of freedom of movement for workers. However decisions No.
ın6
and 1/80,5 whilc making minor improvements to the employment conditions of Turkish migrant workers already settled in the Community, excluded from their scope the most essential prerequisites of free movement : conditions of entry and rcsidence are lcft to the laws of Membcr States. Besides, the EC member States have even refused to harmonise and consolidate the existing bilateral agreements between Turkey and the labour recciving countries at the Community lcvel.Indeed, in spite of Turkey's association with the Community and the principle of free movement, Turkish migrants in Westem Europe continue to feel alienation and rejcction. The uncertainty of their !ega i status is a prime cause of their soeial and cconomic problems. As if to make things worse, the Council of Ministers of the EC, in its resolution of Novembcr 24, 1986, denicd that the frccdom of movement for workers bctween Turkeyand the EC was due to lake effect by Decembcr 1, 1986.6
As stipulated by the Ankara Agreement, such disputes are discussed in the Council of Assoeiation. However the Council of Assoeiation has thus far failed to find a solution. This is not surprising given that under Artiele 23 of the Ankara Agreement, unanimity is rcquired for any dccisions to be adopted by the Council of Association. Furthermore, as far as the Community and its Members are concerned, the decisions and recommendations of the Assoeiation Council has to be approvcd by the EC Council of Ministers by a unanimous vote. This tedious proeedure shows that, despite the principle of supranationality in most intra-Community matters, the Community's extemal relations are largely determined by the Council of Ministers on the basis of the individual interests of Member States.
5Decision No. 2/76, Updating Supp1ement, 30 June 1979; Decision No. 1/80 of 19 Scptember 1980, Brusse1s, CEE-TR 132/80.
4 THE TURKISH YEARBOOK [VOL. XXVII
Turkey's inabiIity to influence the dynamics of the relationship once again became evident in the context of the free movement for workers when, in 1989, the ECJ ('the Court') ruled out the possibiIity of automatic implcmentation for the relcvant provisions of the AssociaLİon Agreement. This judgement reveals a great dea! about the link bctween 'law' and 'politics' in the Community, and, therefore, merits some analysis.
2. The Demirel Ruling
Under Artiele
ı
77 of the Treaty of Rome, national courts may submit any questions relating to the validity and interpretlltion of Community aclS to the ECJ for a preliminary ruling. This is prcciscly what happened in Demirel case.? The Demirel ruling concemed a Turkish woman whose husband had been working in Germany since 1979. She wanted to join her husband in 1984 for the purpose of family unificaLİon, but was only grantcd a visitor's visa. This was justificd on grounds that in the Lander of Baden- Württemberg where Mr. Demirel had been employed, the amount of time that a foreign worker was required to have spent bcfore joining hislher family had been raised in 1982 from three to eight years. As a result of this new Icgislation, Mrs. Demirel was issued with an expulsion order in 1985 on the expiration of her visa. However she challenged the order by appealing to an Administrative Court in Stutgart on grounds, that the new restrictive legislation contravened the terms of the Association Agreement between Turkeyand the EC. For its part, the Administrative Court referred the case to the ECJ for a preliminary ruling.The Court first established, in the light of judicial precedenlS, that it had the necessary authorisation to interpret the provisions in question, since the Assoeiation Agreement was part of Community law. Should the Court role that the relevant provisions of the Assoeiation Agreement were direcıly e//eclive, they would lake precedence over inconsistent national laws of Membcr States. They could then be invoked by Turkish migrant workers.
However the Court denied the direct effect of the frcc movement provisions in the Turkey-EC Assoeiation Agreement. In the Court's view, Artiele 12 of the Ankara Agrcement and Artiele 36 of the Additional Protoeol were in the nature of a 'plan of action' and were not sufficiently precise and unconditiona! to be directly effective. This meant that they could not be relied upon by Turkish migrant workers before national courlS in Germany or elsewhere in the Community.
lt can be argued that the ECJ's ruling was ultimately a 'politica!' one, in that it seemed to have bcen too much concemed about the presence (at the
7Demirel v. Sıadı Schwabisch Cmnd, Case 12/86, European Court Reports, 1987, 3719-3755.
1997J THE CASE OF FREE MOYEMENT FOR WORKERS 5
time) of some 2,5 million Turkish migrants in the Community. The Ankara Agreement was signed during the post-war economic boom when Germany (at the time, West Germany) and other industrialised countries in Western Europe were suffering acute labour shortages. Alongside other countries in the Mediterranean basin, Turkey was encouraged to send its abundant labour surplus into European labour markets, in particular Germany, as is evidenced by the setting up of recruitment offices in Turkey af ter the mid-1950s. However, the deterioration of labour conditions in the EC countries during the 1970s and 1980s, led to the reversal of this policy. In such a milicu, the labour provisions in the Ankara Agreement and the Additional Protoeol began to be perceived by Member States and the Community alike as an 'error of judgement' which had to be remedicd by any means necessary. To that end, the Community refused to adopt Icgislative measures to ensure the progressive implcmentation of freedam of movemenl. At the time when the Demirel case was reviewed by the Court, it was e1ear that the economic and political interests of the EC countries lay in the denial of free mavement provisions as legally enforccable norms. In the end, these 'political' considerations were 'lcgalised' by the Court in its Demirel ruling.
That the ruling of the ECl was politically biased in favour of the national interests of the member states in Demirel case is clear enough. But it is equally suspect from a Icgal point of view. In the past, the ECl had reviewed asimilar case in the context of intra-Community law. The ECL then held that Artieles 48 to 50 of the Treaty of Rame which embodied rules on free mavement for workers were directly effective, and therefore, they could be invoked by individuals in the national courts.8 In Demirel case, the ECl dismissed the paralıcı nature of Article 12 of the Ankara Agreement to Artieles 48 to 50 by drawing on the inadequate level of economic integration between Turkeyand the Community. In the ECJ's view, the Council of Association was to bring about freedam of movement 'in accordance with political and economic considerations arising in particular out of the progressive establishment of the customs union and the alignment of economic policies pursuant to such arrangements as the Council may deem necessary.' (p. 438) But one could equally argue that an association agreement which envisages complete integration on a progressive bases is bound to operate imperfectly. Furthermore, it is the Community which ought to lake the lion's share of the accusation on account of its trade restrictions on Turkish exports. One could also argue that the tightening of immigration policies with regard to Turkish migrant workers has undermined the objectives of the Assoeiation Agreement as set out in Artiele 7 of the Ankara
8Yan Duyn v. Home Office, Case 41{74, Common Market Law Reports,
6 THE TURKISH YEARBOOK [VOL. XXVII
Agreemenl.9 Finaııy, there is little doubt that the ECJ's decision in Demirel case, which declined to challenge the new reslrictive German legislation on family unification, contradicts with fundamental human rights.lO
It is weıı-known that the Court plays a crucial role in EC policy-making.11 It has on occasion went beyond a literal reading of the Treaty which slrikes against the original intentions of its authors.12 It is said that 'whenever the freedom of movement within the common market is at stake, the Court is quick to condemn everything which might stand in its way'.13 This attitude is understandable considering that the Trcaty of Rome laid the foundations for a process of economic and political integration whose final outcome could not possibly be foreseen in detail. The problem, however, is that when this policy-oriented and teleological approach is lransposed to interpret the provisions of international treaties signed between the EC and third parties, this may become an instrument to preserve the interests of the Community and its member states against third parties.
Although they belong to different legal systems, the requirements for the direct effectiveness test are the same for an international agreement of the Community as any piece of Community law. That is to say, both must be 'precise' and 'unconditional' whose impIementation should not be dependent on any further action on the part of the Community or Member States. However, although both are subject to the same test, the international treaties are generally interpreted more narrowly than the provisions of Community law, even if their wording is identicaı.14
While the Court presupposes that the authors of the Treaty of Rome intended to confer rights on individuals, provided that the provisions in question are 'precise' and 'unconditiona!', no such intention is presumed for
9See, for instance, Joseph H. H. Weiler, 'Thou Shalt Not Oppress a Stranger: On the Judicial Protectian of the Human Rights of Non-EEC Nationals - A Critique', European Journal of International Law, 65-91, p. 84. 10lbid., p. 77.
11 F. Snyder, 'New Directions in European Community Law', Journal of Law and Society, Vol. 14, No. I, Spring 1987, 167-182, p. 177.
12H. Jalte Rasmussen, On Lawand Policy In the European Court of Justice, in Jaseph H. H. Weiler, The Court of Justice on Trial', Common Market Law Review, Vol. 24, No. 3, Autumn 1987, 555-589, p. 562. 13Willy Alexander, 'Free Movement of non-EC Nationals, A Review of the
Case Law of the Court of Justice', European Journal of International Law, Vol. 3, No. I, 1992,53-64, p. 63.
14 For an apreciation of this po si tion, see Case 270/80, Polydor Ltd. v. Harlequin Records Shop Ltd., European Court Reports, 1982, 329-358; and, Case 104/81, Hauptzollamt Mainz v. Kupferberg, European Court Reports, 1982, 3641-3679.
1997] THE CASE OF FREE MOvEMENT FOR WORKERS 7
the application of an international agreemenl.15 This interpretative approach gives the Court enough lcverage to deny direct effectiveness in cases involving international agreements of the Communİly.
In Demirel, the ECl renected the views of the EC Member States by avoiding aliteral interpretation of the relevant provisions in favour of a teleological one. This meant that the ECl considered the 'usefulness' of enforcing free movement for workers between Turkeyand the EC excIusively from a Community perspective. The purported objectivity of the Court's legal interpretalİon in Demirel was merely a camounage beneath which an unequal power relationship between the Panies persisted. Referring to the Demirel ruling and the Icgal and political controversy surrounding it, loanne Scott argues that the whole nature of international treaty negotiations are, as a result, put into question : 'It undermines the picture of these as freely negolİated "contracts" which lay down fıxed and cIearly established rights and obligations, the balance of which is mutuaIIy salİsfactory to all panies.'16
Apparently the 'direct effectiveness' test, performed by the ECl, has become a means to marginalise the undesirabIc legal norms contained in Community trealİes wİlh non-member states. Non-dircctly effective treaties are not 'as equal as' intra-Community laws whose direct effectiveness the ECl has been too wiIIing to recognize and, in some cases, establish.17
Three years after Demirel, the Court reviewed another case involving a Turkish migrant worker, this time in the Netherlands. In Sevince, the Court accepted that the provisions of the Assoeiation Council decisions No. 2(76 of 1976 and No. 1/80 of 1980 conceming the conditions of employmem were directly effective in Community countries. Howcver this decision docs not touch upon the rights that are indispensablc for frecdom of movement (entry, residencc, right to remain, etc.) which mcans that it is not relevant to the discussion in question.18 Meanwhile, inKuş19 and Eroğlu20 cases, which
15H. N. Tagaras, 'L'Effet Direct des Accord Internationaux de la Communaute, C.D.E., 1984, 1-2, 15.
16Joanne Scott, 'European Law" in lan Grigg-Spal1& Paddy Ireland (cds.), The Critical Lawyers' Handbook, London: Pluto Press, 1992, 119-126, p. 124.
17For an elaborate analysis of this issue see, Berdal Aral, Free Movement
of Workers Between Turkeyand the European Economlc
Communlty, Unpublished MPhil. Dissertation, University of Kent, 1990, pp. 228-241.
18Service v. Staatssecretaris van Justitie, Case 192/89, 20 September 1990, in Reports of Cases bdore the Court of Justlce and the Court of Flrst Instance, 3497-3507.
8 THE TURKISH YEARBOOK (VOL. XXVII
the Court replied in 1992 and 1994 respcctively, Turkish migrant workers were recognized as having priority over non-EV workers in matters covered by the Council of Association decisions. However the Co urt again dcclined to make any refcrence to the principle of freedom of movement. Similarly, only decisions 2/76 and 1/80 were dea lt with in the Bozkurt case, which the Court reviewed in 1995.21
While initially it was hoped that the existence of a sizable Turkish labour force in Western Europe would contribute to the process of integration between Turkeyand the EC, the 'social' question has turned out to be a major obstacle, among many others, to the deepening of relations between the parties. As is well known, Turkey had applied for EC membership in April 1987 which was (conditionally) rejected in December 1989.22 At the time, Turkey was prepared to accept the suspension of the introduction of free movement for workers as a compromise for full membership.
This aborted attempt did not deter the parties to proceed with the customs union as had becn foreseen by the Turkey-EC agreements. In accordance with the schedulcd timetable, the Council of Association took a decision on 6 March 1995 to establish a customs union between Turkey-EV by the end of
ı
995.23 However, under this arrangement, the EV has undertaken no binding obligations in the field of freedom of movement for workers. The dccision only spoke of establishing dialogue on this issue and19Kuş v. Landeshauptstadt Wiesbaden, Case 237/91, 16 December 1992, in Reports of Cases before the Court of Justlce and the Court of Flrst Instance, 1-6781.
20Eroğlu v. Land Baden-Wurttemberg, Case 355/93, 5 October 1994, in Reports of Cases before the Court of Justice and the Court of First Instance, 1-5113.
21 Bozkurt v. Staatssecretaris van Justitie, Case 434/93, in Reports of Cases before the Court of J ustlce and the Court of Flrst Instance, 1-1475.
22 See, the Commlssion Oplnion on Turkey's Request for Accesslon to the Communlty, Brussc1s, 20 December 1989, SEC (89) 2290 final/2.
23'23. Türkiye-AT 36. Ortaklık Konseyi Toplantısı', 6 Mart 1995, Istanbul, Iktisadi Kalkınma Vakfı, Mart 1995. For a general review of the decision introducing customs union between Turkeyand the EU, see Steve Peers, 'Living in Sin: Legal Integration Under the EC-Turkey Customs Union', European Journal of International Law, Vol. 7, 1996, 411.430. For a critical account of the customs union between Turkeyand the EU, see Erol Manisalı, Gümrük Birliği'nin Sıyasal ve Ekonomık Bedeli, (The Political and Economic Cost of the Customs Union), Istanbul: Bağlam Yayıncılık, 1995.
1997] THE CASE OF FREE MOVEMENT FOR WORKERS 9
seeking possible ways to cope with the integration problem s of Turkish migrant workers in the EU (and the EU workers in Turkey).
3. Current Working and Living Conditions
lt is apparent that the Association Agrcement between Turkeyand the EC has had no appreciable impact on the legal status of Turkish workers living in the Community countries. In fact, for the most part, issues conceming the working and living life of Turkish migrant workers are stiıı regulated by domestic laws of Membcr States and, to a lcsser extent, by their bilateral agreements with Turkey. Not unprcdiCtably, therefore, the number of Turkish migrant workers who have gained extra benefits as a result of, say the Decision No. 1/80 have been relatively insignificant.24 According to the Additional Protoeol, the Council of Assoeiation should have adopted a third decision in 1983 to initiate the final stage of the freedom of movement for workers. However this third stage never materialised. Besides, while visa restrictions for EU countries stili pcrsist, no agrccments have bcen reached by the parties regarding the question of freedom of movement for workers. Even Turkish migrant workers who are aıready settled in one of the EU countries are required to get visa before entering another member country.25
In most respects, then, Turkish migrant workers are stili treated equally with workers from third countries. This is another way of saying that major aspects of their working and living conditions are govemed by domestic laws of host states. The Member States are often reluctant to correct the discrepancies between national laws and the EU law by giying priority to the EU law (Because the Turkey-EC agreements and the Council of Assoeiation decisions are established as part of the EU law). Because of this, even in matters covered by the Turkey-EU law, Turkish migrant workers are not subjectcd to uniform rules at the EU leveı.26
A survey on West Germany just hefore the unification showed that, in spite of the fact that Turkish migrant workers played an essential part in the production proeess, they stili suffered soeial marginaIity in a situation where
24Faruk Şen and Sedef Koray, Türkıye'den Avrupa Topluluğuna Güç Hareketleri (Migratory Movements from Turkey to the European Community), Ankara: Onel Yayınevi, 1993.
25 Şeref Onal, 'Avrupa'da ırkçılık ve Yabancı Düşmanlığına Bağlı Şiddet Olayları ve Alınabilecek Önlemler' (Violent Acts arising from Racism and Hostility Against Foreigners in Europe and Possible Measures Against Thern), Dış Politika, Vol. 5, No. 3, April 1994, 74-100. p. 94.
26Türklye-Avrupa Konseyı ve Avrupa Birliği ılişkilerini ıçeren Sosyal Alanda Temel Metinler (Basic Texts Adopted on the Social Dimensions in Turkey-Council of Europe and Turkey-EV Relations), Ankara: T.C. Çalışma ve Sosyal Güvenlik Bakanlığı, 1996, pp. 227-232.
10 THE TURKISH YEARBOOK [VOL.XXvn
workers and their families were regarded as 'guests' rather than as settlcrs.27 This is in sheer contrast with the undeniablc evidence that the overwhelming majority of Turkish migrant workers have become immigrdnts, and that their children are growing up in Germany with the characteristic traits of second and third generation migrants.
The Icgal unceruıinties faced by many Turkish migrant workers in Germany stiıı persist in the 1990s. It is noted that Germany has been unwilling to act in accordance wiıh the ruling of the Co urt in
Kuş
(and Eroğlu) case, which confirmed the sccond-priority status of Turkish migrant workers. The required domestic laws or regulations to put the Co urt ruling into effect have not bccn issued, except partial arrangements.28 The fact that Turkish migrants have been given the right to dual citizenship in 1998 is surely a positive step in the right direction. However the overwhelming majority will probably not be able to acquire such a status as the requirements are quite difficult to fulfil. Therefore most of the Turkish migrant workers in Germany wiıı continue to strugglc for the enjoyment of various minority rights, at !east in the short or medium term. Such rights include the rccognition of the Turkish immigrant culture and voting rights in local elcctions.Since the faıı of 'communism' in Central and Eastem Europe, and the reunification of Germany in 1989, racism and religious bigotry have dramaticaııy risen in Western Europc. Their economic rool'; are obvious enough. In the specific case of Germany, which hosts a large majority of the Turkish community in Western Europc, the German labour markets have been saturatcd with an abundant labour force from castem Germany and parts of Eastem Europe. This has inevitably deteriorated the position of Turkish
27 Aral, op.c1t., pp. 148-200. However the new Foreigners' Law, which came into force on 1 January 1991, has greatly enhanced the legal status of migrant workers and their families. While tightening up the condİtions for new entrants, the new 'law of aliens' provides for an absolute right of rcsidence for those who have legally taken up employment for acıearly specified period. The conditİons for naturalization have alsa been relaxed, both in materia! and temporal terms. The right to family unification is also guaranteed for those with a proper rcsidence permit. Beat Collet, 'La Nouvelle, Loi allemande sur le sejour des etrangers: changements et contİnuite', Revue Europeene des MIgratlons Internationales, Vol. 7, No. I, 1991, 9-29. In the context of freedom of mavement, however, the new German legislation appears restrictive. This is, for instance, the case with the entry and rcsidence conditions of non-EC workers. Besides, too much discretion is accorded to the administration under this law. Onal, op. cit., p. 95.
28Harun Gümrükçü, 'Almanya'da Yaşayan T.C. Vatandaşlarının Hukuki Durumu' (The Legal Situation of Turkish Citi7.ens Living in Germany), D ıŞ
1997J THE CASE OF FREE MOVEMENT FOR WORKERS 1 1
workers, and singlcd them out as the main 'scapegoal' for unemployment in Germany. In the
ı
990s, the Turks have been among the main targets of inercasing racism and racist attacks against foreign communities in the ED countries.294. Conclusion
The subject of free movement for workers betwecn Turkeyand the EU seems to be bound up with the overall context of their relations. Given that the Council of Assoeiation decision of 1995, which paved the way for the establishmenı of cuSLOmsunion, declines lo regulate this maııer, no formulas other ıhan the Turkish membership of the EU can provide soluıions in ıhis front. However such an evenıuality appears remoler than ever for a variety of rcasons, like ıhe Kurdish problem, human righlS abuses and Cyprus dispuıe, in addiıion lo lhe plight of the Turkish economy.30 Hence, aILhough iıs official assoeiaıion wiıh the EU began nearly 35 years ago (1963), ıoday, Turkey is not included among the Iisı of counlries wailing for EU entry.
IL is clear that Turkish workers are unlikely lo enjoy freedom of movemenl in the EU countries for many years lo come. None of the ED countries seem preparcd lo give free access to Turkish workers in their labour markeıs. Germany has becn most vocal in iıs opposiıion on account of lhe presence of some 2 million Turks in this country. Therefore, contrary to expecıalions, the migratory process of Turkish workers has come to constitute a major obstac\c lo furıhering inıegratİon betwecn Turkeyand lhe EU. Should the unlikely prospecı of Turkish membership of ıhe ED considered on cc again, this issue will most probably be among the hardesı of the questİons ıo be seıLlcd during lhe negotİatİons.
29ün racism againsı, in/er a/ia, Turkish migranı communitics in Europe see, Kadir Canatan, Avrupa'da Müslüman Azınlıklar (Muslim Minorities in Europc), np.: Insan Yayınları, 1995.
30Thcsc vicws were exprcssed by the EV term President Jacques Poos during his visit to Ankara in September 1997, Milliyet, September 2, 1997.
