The US and Germany are among the world's major countries of immigration. The US takes in more immigrants than any other country, and Germany is the chief destination of refugees and asylum seekers in Europe. Nothing suggests the influx of migrants to either country will soon cease.

Population growth in both countries is fueled by immigration. In the US about one-third of population growth is due to immigration; in Germany, 100 percent of the population growth is due to immigration. About eight percent of the 260 million US population are foreign-born, and almost nine percent of Germany's 81 million residents are foreigners. Some foreign-born residents in the US are naturalized US citizens, and about one-sixth of Germany's foreigners were born in Germany (persons born in the US are automatically US citizens; persons born in Germany acquire the nationality of their parents).

Successive German governments have taken the position that "Germany is not a country of immigration." This is not to be understood as a descriptive statement, but as a declaration of policy: it means that Germany does not invite settlement by foreigners. The population of resident foreigners is nonetheless growing, primarily as the result of a continuing influx of asylum seekers, family unification, and births to foreigners living in Germany.

Can Germany and the US, despite differences in immigration history and policy, learn from each other? A March 28, 1995 conference in Washington DC on immigration and asylum challenges and choices in Germany and the US, sponsored by the UC Comparative Immigration and Integration Policy program, the American Institute for Contemporary German Studies, and the Friedrich Ebert Stiftung, heard German experts review recent developments, and Americans draw comparisons with recent US developments.

Germany and the US offer an interesting comparison. Germany proclaims that it does not wish to become a country of immigration, but provides a relatively generous set of services to legal foreigners. The US, by contrast, basks in its immigrant heritage, but provides relatively few public services to help to integrate newcomers.

Managing migration is a tough but not impossible challenge facing industrial societies, and international comparisons will continue to be fruitful. As numbers rise and force action, leaders must be willing to confront the trade-offs inherent in deciding how to manage immigration and integration.

Immigration. The two parts of Germany have been affected differently by migration. The former West Germany added 13 million net immigrants between 1950 and 1993, while the former East Germany lost five million residents because emigration exceeded immigration. The former West Germany included in 1993 about four in five Germans, and virtually all of the seven million foreigners in Germany live in the former West Germany.

Germany is unlikely to remain a country in which foreigners arrive and remain foreigners. If a net 400,000 immigrants continued to arrive annually, Germany would in 2030 have a population of about 90 million, of whom 30 percent would be foreigners. Major cities such as Frankfurt, Stuttgart, and Munich, which are now about one-quarter foreigners, would have populations that were half or more foreign.

Since one in six foreigners in Germany today was born in Germany--1.2 million of seven million--and half have lived in Germany for 10 or more years, the status quo of foreigners remaining foreigners is not likely to continue.

Asylum. Most of the foreigners arriving in Germany over the past five years seeking to settle have arrived as asylum seekers. In Germany and all of the industrial democracies, the majority of asylum applications are rejected, so that separating genuine and false asylum applicants is a major objective of all asylum systems.

When the number of asylum seekers surges, as it did in 1992 in Germany to about 438,000, the cost of housing, feeding, and deciding asylum cases--some DM 6 to 8 billion or $4 to $5 billion--can equal contributions for development assistance (Germany provided $7 billion ODA in 1993).

In 1992-93, there were numerous attacks on foreigners in Germany at a time when over 1,000 foreigners daily were applying for asylum. Germany added resources to speed up the processing of asylum cases, to streamline the system for determining whether a foreigner was being persecuted for political reasons in his country of citizenship, and to return to neighboring "safe countries" asylum seekers who passed through Poland and the Czech Republic en route to Germany.

Most observers consider the asylum reform a success. The number of asylum applicants fell by three-fourths, reducing the state and local costs of housing and feeding asylum applicants. Romanians and Bulgarians learned that it was not worthwhile attempting to get to Germany and apply for asylum. There does not appear to be an offsetting increase in illegal immigration from countries that were sending asylum seekers.

In the early 1990s, the US too faced a huge backlog of asylum applications--over 400,000 in 1995, representing over 700,000 individuals. In January 1995, the US streamlined its system and added more staff to speed up asylum processing. In the US today, an applicant applies to one of what will soon be 327 asylum officers (Germany has 900), and that asylum officer either grants asylum or refers the case to an immigration judge--a non-INS employee. Second, asylum applicants must now wait at least 180 days to work legally in the US.

Both Germany and the US have invented in-between categories for aliens who are not eligible for asylum, but who nonetheless are not deported. The US and German acronyms--TPS, DED, "tolerated"--reflect the expectation that these aliens will eventually depart.

Mass asylum in industrial democracies is a 1980s-1990s phenomenon that has been confronted with more staff to decide cases quickly, and by restricting access to the system. How is the asylum system likely to evolve? Some believe that the concept of safe haven will replace resettlement. Under some notions, ALL persons requesting asylum would be offered safe haven, perhaps on extra-territorial islands. Then, as budgets permit, individual cases would be heard, and those deemed in need of resettlement would be granted the right to begin life anew.

Foreign Workers. Germany recruited guest workers between 1961 and 1973, when their number peaked at 2.6 million, making one in eight workers a foreigner. Over the next 15 years, these foreign workers united their families in Germany, and second and third generation-foreigners joined their parents in the German work force.

Immigration in the 1990s. Germany responded to rising migration pressures from the east after 1989 with five distinct foreign worker programs that involve some 350,000 foreigners, and add the equivalent of about 150,000 full-time workers to the German work force. However, unlike 1960s guest worker programs, 1990s foreign worker programs have a different purpose--to cope with micro rather than macro labor shortages, and to make inevitable migration legal. German foreign worker programs today also have different incentives for the workers involved; the emphasis is on ensuring return to their countries of origin.

The most important program involves project-tied workers. Under this program, German firms sub-contract with foreign firms, and the foreign firm supplies the expertise and workers to complete a particular phase of a project. There were an average 40,000 project-tied foreign workers in Germany in 1994, down from 60,000 in 1992 because of scandals that involved German contractors using project-tied agreements as backdoor guest worker programs.

Most newly-arrived foreign workers are employed seasonally in Germany. A peak 150,000 seasonal foreign workers in 1994 contributed the equivalent of 40,000 FTE to the German labor force. Seasonal foreign workers can remain 90 days in Germany, and most are employed in agriculture, restaurants, or construction. If the workers are employed less than two months, the workers and their employers do not have to pay social security taxes on their wages.

The third program is for border commuters from the Czech Republic and Poland. If local workers are not available in Germany within 50 km of these eastern borders, then employers can request permission from the German Employment Service to employ commuter workers at prevailing wages who can remain in Germany for up to two nights weekly.

The fourth program permits about 6,000 young East Europeans to work and learn in Germany for up to 18 months, although evaluations indicate that Czechs, Poles, and other East Europeans learn few skills in Germany that they use at home. Finally, about 1,000 nurses from the former Yugoslavia are allowed to work in Germany.

In both the US and Germany, there has been a shift in the rationale for temporary foreign worker programs. Instead of recruiting foreign workers to deal with macro or widespread labor shortages, most programs today are justified as a way to deal with a micro labor shortage, or to channel into legal programs inevitable and otherwise illegal migrants.

However, most of the industrial democracies have heeded the advice of the OECD and deregulated their labor markets, and most today play less of a job-matching role in labor markets. The German ES matches about 35 percent of all job seekers and jobs, the US ES three to four percent--giving governments less credibility when considering employer requests for foreign workers.

A complete report of the March 28, 1995 workshop is available from AICGS, 1400-16th St NW#420, Washington DC, 20036-2217, fax 202-265-9531.