influenced by, national institutions. The institutions framed the acceptable discourse and
actions of politicians and interest groups in both countries. For this reason, even though
both countries faced similar economic difficulties, had similar pre-existing anti-racism
laws, and the leading parties in both countries were under political pressure, they
responded quite differently to the directive. The two dramatically differing responses to
the directive are just two of twenty-five responses, each different, each creating a
different right to equality even though they are all founded in one European directive that
is supposed to create one European right. The small amount of variation allowed by the
directive, based on the principle of subsidiarity, actually makes room for a great variation
in implementation, although it does force all member states to enact basic anti-
discrimination law. Without a strong agency or other mechanism to enforce the law,
however, it may remain an empty promise on the books in many European countries. On
the other hand, in countries wrestling with the problems of racism within their societies,
the directive provides an opportunity to improve anti-racism policy and to push the state
beyond old policies. Thus, the implementation of the directive makes clear both its
limitations, as well as the possibilities for progress it may create. It also suggests the
limitations and possibilities of European level social policy making, an important lesson
for the future as Europe moves further beyond its original economic mandate into the
area of social policy.
Convention