Journal of Common Market Studies Vol. 34, No.

2
June 1996

A Categorization of
Differentiated Integration

ALEXANDER C-G. STUBB*

EU Secretariat, Ministry for Foreign Affairs of Finland,
PO Box 176, 001 61 Helsinki, Finland

I. Introduction
The debate about differentiated integration - i.e. the general mode of integration
strategies which try to reconcile heterogeneity within the European Union (EU)
- is characterized by an excess of terminology which can give even the most
experienced specialist of European integration a severe case of semantic
indigestion. Two-speed, multi-speed, step-by-step, strengthened solidarity,
graduated integration, hard core, variable integration, concentric circles, two-
tier, multi-tier, multi-track, two-track, 'swingwing', circles of solidarity, variable
speed, imperial circles, pick-and-choose, overlapping circles, structural variability,
opt-in, opt-out, opt-up, opt-down, bits-and-pieces, ad libitum integration, multi-
level, two-level, restrained differentiation, flying geese, magnetic fields, hub-
and-spoke and many circles, are a few examples of the rhetoric in English. When
adding the French and German vernacular to the debate-plusieurs vitesses, deux
vitesses, intkgration e'chelonne'e, directoire, cercles concentriques, ge'omktrie
' The article is based on a Masters thesis, 'The Semantic Indigestion of Differentiated Integration: The
Political Rhetoric of the pre-1996 IGC Debate', presented at the College of Europe, Bruges, in 1995. The
author would like to thank two anonymous referees and the hollowing scholars for their constructive advice
in the process of drafting this article: Brigid Laffan, David B. Metcalfe, Brent F. Nelsen, Simon J. Nuttall,
Risto E.J. Penttila, Thomas Hagleitner and Per T . Wimmer. Special thanks is extended to Suzanne Innes,
without whom this article would have been an incomprehensible linguistic mix of Finnish, Swedish and
English. All responsibility for shortcomings rests with the author.
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284 ALEXANDER C-G. STUBB

variable, plusieurs niveaux, plusieurs ktages, plusieurs voies, variante unionn-

aire, avant-garde, deux niveaux, noyau dur, noyau solide, diffkrenciation
restreinte, abgestufte Integration, hurter Kern, fester Kern, Kerneuropa and
Teilintegration - it becomes obvious that politicians, academics, civil servants
and journalists alike find it virtually impossible to digest the intellectual menu
of differentiated integration.
From the publication of the Tindemans Report (1975) until the early 1990s,
the supply of quality literature on differentiated integration was rather scarce.
Save the occasional study - Dahrendorf (1979), Grabitz (1984), Ehlermann
(1984) and H. Wallace (1985) - differentiated integration, including its vernac-
ular, was often misunderstood and misconstrued. When the CDU/CSU released
its controversial Reflections on European Policy (1994), the study of differen-
tiated integration was revitalized. Authors such as Quermonne (1994), Gibert
(1994), Maillet and Velo (1994), Chaltiel(1995), Justus Lipsius (1995), Char-
lemagne (1 995), Ehlermann (1995), Wimmer (1995), and H. and W. Wallace
(1995), began filling the lacuna by publishing studies explaining the conun-
drums of differentiation.
Though these scholars have been able to define and illustrate the main
concepts, there still seems to be general confusion about the terminology
involved. The CDU/CSU proposal (1994), for example, calls for a ‘multi-speed
or variable geometry’ Europe, without realizing that these two concepts are
rather different. Moreover, the debate in the European Parliament on 28 Septem-
ber 1994 (PE. 182.022/9),concerning multi-speed Europe, was an embarrassing
portrayal of ignorance concerning the differentiated visions which had been
articulated by Balladur (1994), Major (1994) and Lamers and Schauble (1994).
Ambiguous interpretations, or indeed the failure to understand the true meaning
of the concepts, have caused the various visions launched by party groups and
political leaders to be twisted and misinterpreted. In order to avoid future
misunderstandings, this article aims to define and categorize the confusing and
often overcharged terminology related to differentiated integration.
The article is divided into four parts. The first part defines the three main
categories of differentiated integration - multi-speed, variable geometry and u
la carte-and pegs them to three correspondingvariables: time, space and matter,
respectively. Secondly, the related sub-categories are organized so as to corre-
spond to either one or two of the given variables. The third part of the article
illustrates a few of the most obvious examples of the main terminology. And
finally, the article examines the understanding of differentiated integration of the
Reflection Group, which prepared the preliminary agenda for the 1996 Intergov-
ernmental Conference (IGC). The bulk of the categorization, along with defini-
tions, related concepts, examples, authors and theories are illustrated in Table 1.

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 A CATEGORIZATION OF DIFFERENTIATED INTEGRATION 285

Table 1: Categorization of Differentiated Integration

Variables Time Space Matter
Main Concept Multi-Speed Variable Geometry A la Carte

Definition Mode of differentiated Mode of differentiated Mode of differentiated

integration according to integration which admits to integration whereby
which the pursuit of unattainable differences respective Member States are
common objectives is within the integrative able to pick-and-choose, as
driven by a core group of structure by allowing from a menu, in which policy
Member States which are permanent or irreversible area they would like to
both able and willing to go separation between a hard participate, whilst at the same
further, the underlying core and lesser developed time holding only to a
assumption being that the integrative units. minimum number of common
others will follow later. objectives.
Subhelated English English English
concepts Two-speed Concentric circles Pick-and-choose
and general Step-by-step Opt-in Overlapping circles
jargon Graduated integration opt-up opt-out
Differentiation Two-tier Opt-down
Hard core Multi-tier Bits-and-pieces
Variable speed Two-level Ad libitum integration
Flying geese Multi-level
Franqai s
Orchestrating Europe Variable differentiation
A la carte
Swing wing
Franqais Ad libitum
Circles of solidarity
Plusieurs vitesses Many circles Deutscb
D e u vitesses Imperial circles A la carte
IntPgration khelonnke Restrained differentiation
Directoire Ad libitum
Multi-track
Deutscb Two-track
Abgestufi Integration Multi-floor
Kern Two-floor
Harter Kern Structural variability
Fester Kern Franqais
Kerneuropa Cercles concentriques
Teilintegration GComCtrie variable
Plusieurs n i v e a u
Plusieurs e'tages
Plusieurs voies
Variante unionnaire
D e u niveaw
Plusieurs niveaw
Noyau dur
Noyau solide
Directoire
Diffkrenciation restreinte
Avant-garde
Deutscb
Abgestufte Integration
HarterlFester Kern
Kerneuropa
Teilintegration
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Table 1 (Cont):
Variables Time Space Matter
Main Concept Multi-Speed Variable Geometry A la carte

Examples EMU AIRBUS, ESA UK and Social Charter

Harmonization of VAT ARIANE, JET UK and EMU
Articles: Schengen Agreements DK and EMU
7c, 36,100,115, 1301 EMS DK and defence
Accession Agreements WEU, EUROCORPS DK and citizenship
Transition periods EUROFOR, Derogations
EUROMARFOR ERDF
EUREKA ESPRlT
Articles: Ireland and abortion
J.3(7), J.4(5), K.7,130K

Nature of Supranational Supranational/ Intergovernmental

concept Intergovernmental

Relation to Inside Outside Inside/outside

acquis

Relation to Mainly in pillar I Mainly in pillars 11 and 111 Pillars I, 11, and Ill
pillars

Main uses CDUlCSU document CDU/CSU document

in current Socialist ‘Reflections’ Edouard Balladur John Major
debate Herman Report Alain Lamassoure

Main use in Willy Brandt (1974) Commissariat Gendral

historic Tindemans Report (1975) du Plan (1 980) Ralf Dahrendorf (1 979)
debate Dooge Committee (1984) Jacques Delors (1980) Margaret Thatcher

Main Brandt Tardy Ralf Dahrendorf

authors Tindemans Delors John Major
Lamers and Schauble Lamers and Schauble Margaret Thatcher
Westendorp Maillet and Velo
Quermonne
Kohl and Chirac

Relation to Neofunctionalism Neofunctionalism Functionalism

theory Neofederalism Functionalism Realism
Federalism Realism Neorealism

Position on Maximalist Maximalist/ minimalist Minimalist

integration

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11. Definitions and Variables

When examining the various concepts related to differentiated integration it is
important to distinguish between form and substance. The main concepts, which
are examined more closely in this article - multi-speed, variable geometry and
ci la carte-all have the same form, i.e. they exemplify differentiated integration.
They differ, however, in substance, i.e. they illustrate integration differentiated
by time, space and matter.

Multi-Speed: Time
A multi-speed EU can be defined as the mode of differentiated integration
according to which the pursuit of common objectives is driven by a core group
of Member States which are both able and willing to pursue some policy areas
further, the underlying assumption being that the others will follow later. In other
words, the multi-speed approach signifies integration in which member coun-
tries decide to pursue the same policies and actions, not simultaneously, but at
different times. The vision is positive in that, although admitting differences, the
Member States maintain the same objectives which will be reached by all
members in due time. The concept applies to new policy areas only. That is to say,
the acquis communautaire is to be preserved and developed. In addition, by
setting common goals and objectives jointly at the Community level, a possible
undermining of the Community system and a violation of solidarity are prevent-
ed. Hence, a multi-speed Europe tries to avoid variable geometry and Europe h
la carte solutions, both of which admit to permanent differentiation by maintain-
ing a less ambitious set of common objectives.

Variable Geometry: Space

The second main concept, variable geometry, can be defined as the mode of
differentiated integration which admits to unattainable differences within the
main integrative structure by allowing permanent or irreversible separation
between a core of countries and lesser developed integrative units. A Europe
differentiated by space (explained below in relation to matter) goes further in
institutionalizing diversity than integration differentiated by time. Whereas
integration differentiated by time defines and maintains a wide range of common
objectives and goals, integration differentiated by space takes a less ambitious
approach by considering that European political, cultural and economic diversity
makes an ambitious set of common objectives both unrealistic and unattainable.
According to this view Europe, due to its diversity, will and should always
organize itself around a multitude of integrative units.

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A la Carte: Matter
The third main concept of differentiated integration is a pick-and-choose or a la
carte Europe. By definition, the culinary metaphor of a Europe h la carte allows
each Member State to pick and choose, as from a menu, in which policy area it
would like to participate, whilst at the same time maintaining a minimum number
of common objectives.' This approach is focused on matter - i.e. specific policy
areas. All countries are in the first circle in which they can choose their own
suitable matter of participation - be it social policy, monetary policy, or defence
policy. This stands in stark contrast to both a multi-speed Europe, which defines
common objectives towards which Member States strive (in due time) according
to ability; and variable geometry, which institutionalizes differentiation of the
Member States so as to create space between the various integrative units or
forms of integration.

Comparisons
Multi-speed and h la carte are at the two extremes of the spectrum of differen-
tiated integration. Both concepts work within a single institutional framework
and maintain the established acquis communautaire, the main difference being
that multi-speed maintains an ambitious and often supranational set of common
objectives which will be reached by all Member States in due time, whereas the
h la carte solution maintains a less ambitious and intergovernmental view of
integration in which common objectives are sacrificed on the altar of national
interest, and hence each Member State is able to pick-and-choose in which policy
area to participate.
In its ambiguity, variable geometry exemplifies the middle ground between
multi-speed and h la carte. This form of integration is differentiated by space in
that it recognizes permanent differences among both the core and periphery, thus
creating various conglomerations of integrative units. By definition, variable
geometry is more integrationist than h la carte.The former can create a hard core,
which drives for deeper integration in a specific policy area, the latter is usually
characterized by miscellaneous co-operation in areas that are not considered to
intrude on national sovereignty. The difference between variable geometry and
multi-speed is the degree of common objectives involved. Variable geometry
takes place outside the acquis communautaire and, as opposed to a la carte, has
a tendency to push for various forms of deeper integration outside the regular
decision-making structure of the Union. Multi-speed, on the other hand, has the

I While realizing that Dahrendorf's (1979) definition of ci la carte was originally designed to challenge the
notion of a hard and immutable acquis communaufaire, this article uses the 'modem' pick-and-choose
definition of a la carte.
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 A CATEGORIZATION O F DIFFERENTIATED INTEGRATION 289
most ambitious acquis and avoids any form of differentiated integration outside
the Community structure.
Whereas time is a rather self-evident variable for multi-speed, the distinction
between space and matter - corresponding to variable geometry and u la carte
- is more blurred. All three sub-categories of differentiation obviously involve
matter, i.e. various policy areas.* Moreover, they all have institutional implica-
tions. The reason that this article pegs matter to u la carte, is that it is the most
obvious example in which the focus of differentiation is on scattered policy
areas. Space, on the other hand, is used as a variable because the quasi-positive
connotation of variable geometry is, firstly, a metaphor drawn from aeronautical
innovations (H. and W. Wallace, 1995)and, secondly, because the various larger
areas of co-operation which illustrate variable geometry maintain their own set
of common objectives- a number of these conglomerations create a certain space
between each other. In its simplest terms one can say that variable geometry is
more integrationist than u la carte. The main distinction between variable
geometry and u la carte is that the former exemplifies a certain opt-in or opt-up
to a conglomeration of Member States which have already pursued deeper
integration in a specific policy area (e.g. the Schengen Agreements). The latter,
on the other hand, is a form of differentiation in which a Member State opts out
or opts down away from a specific policy area (e.g. the UK and the Social
Chapter).

111. Related Sub-categories

There is an excess of related sub-categories of differentiated integration which
can be organized as follows.

Multi-Speed: Time
The notion of multi-speed integration holds a number of subvariants which
correspond roughly to the same form of differentiation. Concepts that relate to
integration differentiated by time include two-speed, step-by-step, variable
speed and graduated integration. Moreover, the notion of a solid or hard core as
the driving force of further integration can be pegged to the multi-speed concept.
The jargon in French is equally vast: plusieurs vitesses, deux vitesses and
intkgration e'chelonnke can all be considered as concepts that correspond to
integration differentiated by time. And, as in the English language, the terms
noyau dur, noyau solide and directoire signify an important part of multi-speed
* For this point I am indebted to Simon J. Nuttall, Claus-Dieter Ehlermann and Per T. Wimmer who, each
in his own way pointed out that matter is a decisive factor in both variable geometry and 6. fa carfe.Despite
their sage advice to integrate the two variables of space and matter, I persistently stick to my trinity
categorization by claiming that there is a fundamental difference between variable geometry and u la carfe.
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integration in which a conglomeration of Member States creates a centripetal

force which counteracts the centrifugal force of enlargement. Adding to the
semantics of multi-speed differentiation, the German literature on the subject
provides terms such as abgestufre Integration, hurter Kern, fester Kern, Kern-
europa and Teilintegration.

Variable Geometry: Space

The notion of variable geometry also has numerous similar subvariants. Integration
differentiated by space thus comprises the concepts of two-tier, multi-tier, two-
level, multi-level, ‘swing-wing’, circles of solidarity, many circles, imperial
circles, restrained differentiation, multi-track, two-track, multi-floor, two-floor,
opt-up, opt-in and structural variability. Much as with multi-speed, the notion of
a solid or hard core as the driving force of further integration can be pegged to
the variable geometry concept. The French terminology includes: cercles
concentriques, gkomktrie variable, plusieurs niveaux,plusieurs ktages, plusieurs
voies, variante unionnaire, deux niveaux, noyau dur, noyau solide, avant-garde,
directoire and diffkrenciation restreinte. These can all be considered as concepts
which correspond to integration differentiated by space. As well as relating to
multi-speed integration, the terms noyau dur, noyau solid and directoire, signify
an important part of variable geometry integration in which a conglomeration of
Member States create a momentum for further integration by opting up to
integrative units which want to pursue a deeper pooling of sovereignty outside
the acquis communautaire. Similarly, the German terms -abgestufreIntegration
and Teilintegration, along with the standard definitions of Kern, hurter Kern,
fester Kern and Kerneuropa - relate to both multi-speed and variable geometry.

A la Carte: Matter
Though Europe a la carte is the most metaphorical of the main concepts which
relate to differentiated integration, it has significantly less subvariant jargon. The
English language contains related terms such as pick-and-choose, maximum
flexibility, opt-out, opt-down and bits-and-pieces. The term la carte, derived
from French culinary tradition, does not have any subvariants in the French
language. The German language, equally poor on parallels, borrows its h la carte
metaphor from Latin: ad libitum. The lack of synonyms for a la carte can be
explained by the fact that the metaphor is self-explanatory. It is easy to
understand that according to this form of differentiated integration a Member
State is allowed to pick-and-choose, as from a menu, from respective policy
areas - not even the most uninformed journalist or politician should be able to
misunderstand or misconstrue this concept.

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Comparisons
It is evident that with such an excess of metaphorical terminology, both the
academic and political debate - concerning the Intergovernmental Conference,
for example - suffer from a certain sense of incoherence. It is to try and prevent
this confusion that I have provided this threefold categorization. The terminol-
ogy relating to multi-speed - which in one way or another can be identified by
established common objectives, reached at different points in the integration
process - can be categorized under the general variable of time. The cousins of
variable geometry, on the other hand, can be organized under the general variable
of space. And finally, the notions of scattered policy integration with a minimum
number of common objectives, are found under the variable of matter.
I should emphasize that this categorization is by no means exhaustive. It is,
however, an attempt to bring clarity to an array of concepts which have a
tendency to be either lumped together under the general heading of differentiated
integration, or simply mixed with related terminology. In addition, it should
provide a means of categorizing various forms of differentiated co-operation and
integration, both inside and outside the European Union.

IV. Major Examples

Multi-Speed: Time
Transition periods and temporary derogations, often related to accession agree-
ments, are the most evident examples of multi-speed integration. Some of these
periods are quite long, up to ten years, but they are never unlimited. There are also
a number of other examples of multi-speed integration which can be found in
both the Rome Treaties and Treaty on European Union (TEU). Art. 7c of the EC
Treaty, for example, allows for temporary derogations for lesser developed
economies. The aim is to allow all Member States to achieve the objectives set
out in Art. 7a. In addition, Art. 115 allows Member States to take temporary
protective measures against products imported from third countries.
The Treaty on European Union introduces a very important element of multi-
speed into the development of Economic and Monetary Union (EMU). Under the
terms of the Treaty, the European Council is obliged to decide whether a majority
of Member States have fulfilled the convergence criteria and are ready to go
forward to Stage I11 of the EMU and to adapt to the single currency. Save
Denmark and the UK (this illustrates that a specific policy area can have many
forms of differentiation), the Member States have set out common objectives
which are to be reached in due time. At first sight the EMU arrangements
correspond to the notions of desire and capability which are related to variable
geometry, but since the countries have tied themselves to a timetable and a set
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of final objectives within the framework of the acquiscommunautaire,the EMU

arrangements have a closer connection to multi-speed.

Variable Geometry: Space

Within Europe, and associated with the EU, there are a number of examples of
variable geometry.3 In defence, peace-keeping and crisis management, variable
geometry is illustrated by the WEU, EUROCORPS, EUROMARFOR and
EUROFOR, where a number of Member States have opted-up by participating
in deeper integration outside the acquis communautaire.And in the sphere of the
third pillar, the Schengen Agreements could be considered a good example of a
conglomeration of states which pursue deeper integration within a separate
integrative unit. These differentiations are not a form of multi-speed integration
because they are not a part of the common objectives established in the Treaty
on European Union. Nor can they be considered as examples of h la carte
integration mainly because they are forms of opting-up/in, as opposed to opting-
down/ou t.

A la Carte: Matter
There are a number of opt-out clauses in the framework of the Maastricht Treaty
which correspond to the notion of h la carte integration. Both Denmark and the
UK wrung concessions from their partners in the policies of Economic and
Monetary Union (Protocols 11and 12).These so-called opt-out clauses were not
temporary derogations; instead they gave both countries a permanent right to
remain outside the EMU. Another derogation was added by the Danes to include
the common defence policy. And finally, a substantial opt-out is the British
Social Protocol (Protocol 14). To overcome Britain’s stringent position on
national sovereignty in social policy, the other 11took all seven of the new social
policy articles and agreed a separate Protocol among themselves. This was the
first time that the Community sought a fragmented h la carte solution to an entire
policy area.
The most recent form of h la carte is illustrated by the Swedish accession
agreement, which permitted the continued use of snus (snuff), the Swedish
national vice, despite its being illegal in the rest of the Union. The reason was
pragmatic: of Sweden’s 8 million eligible voters, over 10 per cent use snus and
these 800,000 ‘snuffers’ were regarded as essential for securing a ‘yes’ majority

It has been pointed out that the term variable geometry was used earlier in the realm of industrial policy
where different Member States would participate in different programmes such as JET, Airbus, Ariane and
Eureka, mainly because they chose to invest in a particularpolicy outside regular Community action (H. and
W. Wallace, 1995). These examples do not, however, play a major part in the overall dynamics of European
integration. Hence, they should be considered as minor examples of variable geometry.
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in the Swedish referendum. This point illustrates that even a la carte solutions
can be used for the benefit of the Union.

V. The Reflection Group’s Report and Differentiated Integration

The Reflection Group preparing the 1996 IGC published its final report in
December 1995 (SN 520/95 REFLEX 21). Though the Group’s progress report
(SN 509/95 REFLEX 10) portrayed a certain inconsistency in the use of
terminology related to differentiated integration, its final report outlines a clear
vision for the limits and possibilities of flexibility within the Union.4
In essence the Group rejects any formula which could lead to an la carte
Europe. It maintains that flexible solutions, mainly multi-speed, can be used if
the following criteria are met: flexibility should only be allowed as a last resort
and if the differentiation is temporary; those willing and able should not be
excluded from full participation in a given action or common policy; and when
allowing flexibility, the acquis and the single institutional framework must be
respected.
The report also points out that the degree of diflerentiation admissible varies
according to the pillar and also between the present Member States and those
acceding in the next enlargement. The formula is such that derogations will not
be allowed in the first pillar if they jeopardize the internal market. However, the
Common Foreign and Security Policy (CFSP) and some Justice and Home
Affairs issues enable a greater degree of flexibility. The method used with
acceding countries should in principle be transitional periods based on specific
circumstances.
In sum, it seems as if most Member States are willing to accept differentiation
as long as it is temporary and as long as the single institutional framework and
the acquis communautaire remain intact. This means that multi-speed integra-
tion will continue to be used. A la carte integration is rejected outright. Variable
geometry formulae, on the other hand, are difficult to predict since the Reflection
Group’s report does not consider them explicitly. Nevertheless variable geom-
etry, if defined as the possibility for deeper integration outside the Community
framework (hard core), could become the vital issue related to differentiated
integration in the 1996 IGC. Whether variable geometry will be established in the
Treaty, as suggested by Chancellor Kohl and President Chirac in an open letter
on 6 December 1995, remains to be seen.

It is interesting to note that academicanalysisoften uses the term differentiated integration, and the political
world has a tendency to talk about flexible integration.

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VI. Conclusion
The European Union is facing a plethora of internal and external challenges. One
of the internal challenges is to build a Union to which its citizens can relate.
Externally the Union must assume increased responsibilities in the international
community by giving itself the means to more effective and co-ordinated
external action. The main challenge, however, is to make the necessary institu-
tional, procedural and policy changes so as to ensure the effective functioning of
an enlarged Union. Since expansion leads to diversity, the Union will have to be
flexible enough to embrace varying patterns of integration. Unpalatable though
it may seem, the Union might have to accept the inevitability of a differentiated
future - without in the process allowing its decision-making process to become
hopelessly cumbersome. Widening and deepening - enlargement and integra-
tion- will not prove easily compatible. Hence, in responding to these challenges,
differentiated integration, using variants of multi-speed and variable geometry,
might provide the necessary solutions.
This article has made an attempt to illustrate that the semantics of differen-
tiation provide a plethora of complex integration strategies which are often
difficult to conceptualize. The categorizations, examples, general characteristics
and definitions given offer a method by which one can find both clarity in the
debate and a more profound understanding of the concepts which relate to
differentiated integration.

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