By request, I am crossposting my post on becoming a German citizen for discussion here.
Hello fellow Mottizans, I have emerged from my lurker cave to share good news with you all: I have become a German citizen! But not through naturalization or birth; I used an uncommon route with a new and somewhat strange process: a StAG section (§) 5 declaration. While going through this, I had learned a lot about that citizenship laws of Germany and some comparisons with other countries, as well as spending (too much) time browsing various expat and citizenship forums and subreddits. I’d like to subject you to share with you what I’ve learned in this weird journey, through intergenerational citizenship and questions of national identity.
Background
With so many immigrants out there, why should you listen to me, an American moving between western countries? Well, I, personally, value it more when people put in effort for something with less assured payoff; few want to split lottery tickets, everyone wants to split the winnings. Similarly, I moved to Germany as someone with only German heritage, as a normal immigrant, and then more than a year after that a new law offered me a privileged path to citizenship through legal magic. In short, I committed to Germany and then received the winning lottery ticket.
A bit more about my path: I moved to Germany in 2020 with the EU Blue Card for highly qualified immigrants. I chose Germany because part of my family was from Germany, and in the typical American style I considered myself German-American. I had visited Germany and liked it, although I knew visiting and living somewhere are two very different things. But what I would really like to stress is that visiting Germany felt like visiting a home, a place that felt natural. I’ve visited plenty of other countries, and everywhere else it was clear that they were foreign, “alien” countries. It was obvious when I was in Japan that no matter how much I might like visiting castles or eating ramen, Japan would remain a foreign country. When it was unclear whether I would be still working in Germany, a friend suggested that I work with them in the Netherlands, and a big hangup was that the Netherlands was a foreign country, this despite the fact that they speak more English and I would be around more English-speaking expats. Germany was the ancestral homeland, and no other country could ever replace that.
German citizenship is based primarily on jus sanguinis, citizenship by blood: someone is a German citizen at birth because their parents were citizens. But this was, in the past, primarily patrilineal. In fact, the German citizenship in my family was cut off when my German grandmother married a foreigner: she automatically lost her German citizenship, rendering her stateless and all her children non-Germans, including my father, and all of her grandchildren were not German either, including me.
In August 2021 Germany passed an amendment to the Staatsangehörigkeitsgesetz (StAG), or nationality law. The new StAG § 5 allows those who, to quote the federal authority, “were previously excluded by gender-discriminatory regulations from acquiring German citizenship at birth may now acquire it by way of declaration. Briefly, the post-war German Basic Law (a constitution) forbids gender discrimination, and so those who were excluded from acquiring citizenship due to this gender discrimination could claim it back; for example, until 1975, German women would not pass down citizenship by default. The process is new enough that the relevant authority here in Germany, in a major city, did not know about it. But I collected all of our old documents, submitted my application, and now (as of the time of writing) the certificate is in the mail in hand!
I did it, I became a German citizen! I did not naturalize, I gained citizenship through declaration (queue up, “I didn’t say citizenship, I declared it!”). I did not have to reside in Germany for 6-8 years, I did not have to speak German, pass any test, pay any money or do anything at all but submit a few documents and citizenship was handed down in a puff of magical legal smoke by a bureaucrat I’ve never met before. If I suffered some brain damage I could commit terrorism or racially motivated crimes, things that would have excluded me before, and still keep the citizenship (I don’t think I’ll test that though). And my children will also be German citizens from birth, and their children, and so on forever, just as it had been passed down to me from forever ago (well, at least since 1871).
But importantly, I haven’t been saying that I became German. I don’t speak German, I didn’t grow up in Germany, and neither did my parents. By the Basic Law, I am a German because I hold German citizenship, but I try to look past the purely legal standing. I don’t think the idea of who is German has a really clear and universal answer; different people and different Germans give different answers. Perhaps we can talk about the traits of Germans, but until we have access to the pure and perfect German Form, arguments are really all we can get. I will reference that concept of being a German plenty though, and the legal vs. cultural German.
That gives my background and stake in the matter, and it will make for a nice dinner party story but isn’t that important. In fact, nothing really changes legally for me anyway, my permit covered it all before. I think it’s much more interesting to talk about what I’ve learned along the way, as it might actually be interesting and useful for everyone else. So here it goes!
The Strangeness of Descent Laws
German citizenship by descent is a mess, but it’s interesting to take a little dip into the law. Before I only said that German citizenship is based on descent, which glosses over many of the complications that arise in tracing that path. A nice guide on the process can be found here. The US (and most countries in the Americas) use primarily jus soli or birthright citizenship, i.e. you are a citizen of a country if you are born in that country, but also has citizenship by descent. But it’s much more restrictive; in particular, while German citizenship by descent is basically limitless, US citizenship by descent requires that if e.g. the child has two citizen parents, at least one resided in the US at any point, or if only one parent is a US citizen they must have resided in the US for at least five years. I call this a “sunset clause” in citizenship, something that terminates citizenship automatically without a connection to the home country.
Without a solid sunset clause in the German citizenship by descent, you get some (in my personal view) strange lines of descent. Someone whose great-great-great-grandfather left Germany in the late 1800s can be a German citizen directly if it happens to pass only through the male line in key years. Compare this to someone whose German mother married a foreigner and they were born in 1948; their path to citizenship would be under StAG §14, and they have to establish a close connection to Germany, such as speaking German and having close family members in Germany. Here we see that you can only be a legal German if you establish that you are already a cultural German. Add on to this complications such as if your parents naturalized before or after you were born, if you served in a foreign military, if you every voluntarily gained citizenship of another country, and it gets complicated. To note, Germany has added a sunset clause: if a German citizen is born abroad after 1999, any of their children born abroad only retain German citizenship if the authorities are notified before the child’s first birthday. No more surprise citizenships by descent a hundred years down the line.
All of this has led to a lot of people sorting through old paperwork to find out if they are secretly German citizens or can become one. I like to point to the growth of /r/GermanCitizenship as part of it, but the perhaps better known example is for Italy, where it is popular enough to have consular wait times in years and a CNN article about it. I’ll just voice my personal opinion that all of this is a little strange to me; when one out of sixteen or thirty-two of your ancestors at a particular level came from a particular country, it’s hard for me to see where exactly your connection comes in. The legal case may be perfectly fine, but the cultural part falls through. I normally see it chalked up to “honoring ancestors” or “keeping their memory alive,” which turns into an excuse to have a nice passport and travel the EU visa-free as far as I’ve seen.
And I should mention that Germany, in principle, discourages dual citizenship. If you naturalize, you normally must give up other citizenships, if it is possible and doesn’t cause undue hardship. Notably, the fees to renounce US citizenship are high enough that the authorities may permit you to keep US citizenship if you make less per month than the fees, $2,350. It also permits dual citizenship if other citizenships were gained automatically, i.e. from birthright. There are many exceptions nowadays, but the principle still exists, and causes problems sometimes when e.g. people are forced to choose a nationality.
Finally, I will point out that StAG §5 vs. §14 (post- vs. pre- Basic Law) seems weird to me. A German woman could lose her citizenship by marrying a foreigner in e.g. 1947, have a child in 1948 then one in 1950; the first would have to prove their ties to Germany, while the second would get in without any restrictions, but in both cases the relevant legal situation that caused the loss of citizenship is the same and only stopped in 1950(ish). For the second child, the claim would be that because the Basic Law forbids gender discrimination, they were unfairly discriminated because they should have been able to obtain citizenship from a female parent. I’m not a jurist but the legal idea seems fraught: how could laws prohibiting an action in the future justify retroactive corrections? But §5 covers much more than that, affecting people born as late as 1993.
But the biggest takeaway from all of this is that I have the impression that citizenship laws oftentimes are capricious and arbitrary, relying on old documents that some may or may not have and offering various paths or restrictions that change over time. Countries try to both preserve a legal basis for citizenship while trying to reasonably restrict it, while working under changing social views and massive changes in the way the world works.
I think a look at the citizenship laws is helpful mostly to find out that they don’t really answer anything but a legal question, which is important but not what I’m after. I hope no one thinks that someone born to a German mother and a foreign father in 1974 is definitely not a citizen while a sibling born in 1976 definitely is, even if the legal situation is clear.
The Reddit Expatriation Community
That’s enough about citizenship laws then. I was fascinated by (potential) immigrants, especially on Reddit, that I came across in my browsing. As an American, I grew up with the idea that America was the land of immigration and that immigration only really flowed one-way. I think the statistics bears this out, with the US having one of the lowest shares of its population living abroad. Why would someone leave the freest and richest country?
I feel like this is changing, slowly. As other countries become richer, it becomes less clear that America is the automatic best option, and it is probably easier; I can do things like videocall my parents every week and translate written text on my phone, things that make it vastly easier to emigrate. And let’s be clear, the advantage of being a natural Anglophone is huge. On Reddit, which I think is primarily dominated by Americans and Anglophones in general, some of the migration-focused subreddits have seen a lot of growth: Amerexit, iwantout,and expats. Those are my three favorite (or at least most entertaining) subreddits, and they run the gamut from “America sucks, I want to leave!” to “How can I leave my current country (serious answers only)?” to “Living in a foreign country sucks in so many ways.” Pick your favorite, I guess. And like in everything else, politics is the mind-poison in immigration. But there are many common themes; I’ll reference posts without linking to avoid inter-subreddit drama.
I think most of these immigrants, and probably most immigrants in general, are what I would call “materialist immigrants.” Most people are looking to improve their economic situation or living standards. How they rate these things is up to them; someone may value high salaries directly, while others value more consistent healthcare coverage or walkable neighborhoods. If they’re from a western country they may consider themselves (and others like them) an expat instead of an immigrant, but it all amounts to the same thing. Even that German citizenship guide I linked before explains the benefits of becoming a German citizen in almost purely economic terms: live and work in the EU! Travel visa-free in so many places with a German passport! Go to university for free! If you’re destitute, Germany will take care of you! Drawbacks: none, you don’t have to learn German or pay any taxes or do anything at all for anyone else.
And the discussions reflect this living-standard/economic focus, and an entirely Ameri-centric view. Currently in /r/AmerExit, someone is hating on the US because… (checks subreddit) they can find cheap mineral water while on vacation in Italy. No, I’m not joking, it’s the first point in a top post at the time of writing. Someone may fear American politics enough to instead move to Turkey, a country that literally went through an attempted military coup in 2016 and has a nice book review regarding Erdogan-as-dictator on ACX. Or a contemporary favorite, overlooking the fact that many countries have more strict abortion laws than some US states.
When looking for somewhere to go, I see so often that people think of moving to completely different countries, treating them all the same as if “western European” covered everything they need. One person might say Germany and… Wales? How about the Netherlands, Spain, Italy, Germany, France or the UK? Another might want to move to Ireland or Scandinavia, but they speak fluent Spanish. Countries are interchangeable, as long as they have some greenery, good weather and everyone there aligns with their values. Everyone is “willing to learn the language,” a completely costless declaration that I always translate to, “I may learn to swim if you throw me in the middle of the ocean.” Even at the end of the natural process, I can see someone declare that they are finally an “EU citizen” after eight years as if their citizenship was granted by Brussels and not their home country.
Beyond the standard internet/Reddit stupidity, these feel like they cover an individualist- and money-focused worldview. And it naturally feeds materialist immigration that disregards the people who actually live in these places, which causes critical problems in adjusting to a life in a foreign country. Remember what I said about /r/expats? It’s the opposite version of /r/AmerExit, where people have gone to a foreign country and found that, yeah, it’s not America. This is what happens in the culture-clash. The day-to-day reality of living in a country that sees the sun for a few hours a day in the winter sets in. Of dealing with people who will always treat you like a foreigner. Of being far away from family and former friends. It’s tough to live somewhere far away from home, and it’s tough to know that before you actually make the move.
But… why is it tough? I haven’t seen many expats complaining about their jobs, most complain about the people around them and their social life. And the world seems very thoroughly Americanized: I visit American-style department stores, see advertisements in English, I can almost always ask to speak English with people, it all sounds very convenient to and for me. They have the healthcare and sparkling water they so desperately desired. What’s missing? Why can’t they assimilate?
Part 2 follows.
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Notes -
First off, willkommen daheim.
You're the kind of immigrant I wish all immigrants were, and I further wish that our immigration policy and infrastructure were modeled in support of this desire as opposed to the materialist cosmopolitanism they currently support. But let that be all for politics, in so far as I can keep myself in check, because that's spoken of frequently enough on the Motte.
Instead, Heimat.
Heimat is probably the most important concept in my life. At best I feel somewhat reduced when away from it, at worst outright uprooted. Heimat is source of great strength and comfort. It also seems impossible to communicate its meaning to anyone who does not already know it. And sadly more, many people who reveal a preference for it still consciously and publicly reject the concept. But you profess to have migrated for it. And I believe you. Heimat is at least slightly different for everyone, and many people will try to reinterpret it to mean something more urban and cosmopolitan than it usually does, but you come here and accept the term as-is, explaining it almost exactly as I myself would understand it.
You mentioned your Grandmother's cooking and her insistence on your father's Germanness - what did the latter imply? How German was your father, and how German was your upbringing? What other points of contact did you have with German culture? How come you could accept Germany or some specific part of it as your Heimat when you were born and raised an ocean away?
There are two components very central to my conception of Heimat that I have a hard time imagining you accord similar importance to: Language and Landscape.
Language is probably obvious. Some historians and poets described Germany as a nation of one tongue (though with many dialects, of course), and it makes sense to me - genetically we're fairly mixed for all that I know, and Germany has no real political founding myth either. Language though, that seems to work for German ethnogenesis. And it works for me personally - when I hear my dialect spoken, I know I'm home. When my child is so far barely able to string two words together but consistently renders those in dialect, I know that she and I will share a piece of Heimat. But you describe your German as minimal, so does language actually feature prominently in your Heimat?
Landscape is another one. That one is probably less obvious than I feel - most people nowadays spend the majority of their time indoors, and most step outside only to find themselves in artificial, urban spaces. But whenever I lived in a city, I felt distinctly heimatlos. It's even worse now that I'm back in the countryside; visiting large towns and cities feels like entering a completely different country. And I don't just mean that they're cramped, filthy and full of foreigners - I mean you can't see the landscape. Standing in a city, for all that I can see, I really might be in any other country. But it's not just urban/rural. When I visited the North a few months ago, I was constantly amazed by people's ability to live in a landscape so flat and featureless. Granted, they have the sea, which is awesome, I envy them for that, but still - the act of climbing a hill or traversing a valley cannot come naturally to them, similarly to how I'm usually left awestruck when I visit the alps and see actual mountains. The point of all this being - landscape shapes the mind. But you must have grown up and lived in a completely different landscape, with views very unlike those where you live now. Maybe you even live in a city now. So I'm guessing that landscape also is not a core part of your Heimat.
I'd branch into some other components as well - like, architecture: What an effect does seeing Fachwerk have on you, if any? Or soundscapes: How do you feel about cows and churchbells and the cries of hawks? But those are often so strictly regional that there's probably no common ground unless you happen to live next door.
In any case, gute Nacht.
I think that the Heimat and being German (or any other identity) is less about a current state and more about what could be called an attractor, i.e. it is not a single state to achieve but a point which one approaches. Germans have continuously changed, and each one has their own different identity. But languages, food, architecture, and even landscapes evolve over time; did the Germans of 1500 have less "German" cuisine than the ones today because they did not have the potato? I wouldn't say so; instead, the cuisine evolved over time, took in new items from the Columbian exchange and throughout remained German. This is easy when you are already in the attractor, as you evolve with it and all together, but if you're outside it's not trivial to get close enough to the attractor to latch on, especially when you have to leave another safe and comfortable one.
I don't think my upbringing was particularly German, the points of contact were minimal, and it's tough to describe the water you swim in anyway. But I think the American identity is particularly flexible and mutable, and makes it easy to have a secondary identity. I've sometimes thought of the American identity as being like white paint; if one mixes other colors together they tend towards brown, but mixing a color with white paint tends towards that color, and in the same way mixing the American identity with others is easier than mixing two other identities. And that preserved identity provides a Schelling point when fixing an identity out of all the myriad options; I was able to swap attractors a little easier than others then when it came time. It probably helps that I grew up in the Midwest.
I think language is one of the most important parts of the Heimat! My father grew up in a home that spoke mainly German, but by the time I came around most of that is lost. It's something I do wish I had taken, and now it feels like being separated from everyone else by a glass wall where I can mime the actions but I remain cut off. I should be learning German more and taking classes, but the akrasia is real. Still, I think that I am pushed more to learn German on my own than e.g. my wife, who has taken classes and done more formal work but speaks less than me. That heritage provides impetus, and a willingness to learn German qua German instead of German qua "the language I need to get around in this foreign land." It's funny that you bring up dialects, because when I travel around Germany now I definitely notice the accents and feel much more at home when I return and hear the accent change back!
I grew up in the Midwest, and the rolling green hills are just as present there; I try to spend plenty of time outdoors (is that not also a German thing?). When I first came to Germany it was for work, and when I eventually moved it was to the same location. Part of that is because the terrain matches so well. I also lived for a time in the American Southwest, and it was obviously different: dry sage fields as far as the eye can see, orange-red canyons, bare rocky mountains, etc. I liked it, but only some parts, and it was obviously not home. I do think it's interesting that the more Hispanic Southwest matches Spain while the more German Midwest matches Germany more. I do live in a city, and I would echo your sentiment about it being more artificial and globalized than the countryside, but it does ok; I still get to attend the Volksfeste in the local Platz.
I'll end with a note that my grandmother was from east of the Oder-Neisse line. My core Heimat from my family is completely gone, forever. There are things I find strange that the local Germans find normal and vice-versa. But identities can spread out too, so I take up the broader German identity while I build up a new one where I live. I'm sure my children will have a different Heimat than I do, but they'll always be caught in some of the same attractors.
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