Migration Politics in East Asia: Comparing Japan, South Korea, and Taiwan | East Asia | bpb.de

Migration patterns in Eastern Asia are characterized by 1) intraregional migration flows, 2) return migration of former emigrants and their descendants, or co-ethnic immigration, and 3) marriage migration. With the third, eleventh, and twenty-first largest economies in the world (in 2020), Japan, South Korea, and Taiwan are the dominant migrant-receiving destinations in this world region. In 2020, the number of foreign residents in Japan grew from 850,000 in 1985 to almost 2.9 million, with the largest streams coming from China, the Korean peninsula, Vietnam, the Philippines, and Brazil (see Figure 1).

South Korea’s foreign population grew more than forty-fold in three decades, from less than 50,000 in 1990 to over two million, with the largest numbers from China, Vietnam, and the Philippines (see Figure 2). While smaller in scale than Japan and South Korea, Taiwan also experienced a more than three-fold increase in its foreign population, from a little over 250,000 in 1995 to almost 800,000, mostly from Indonesia, Vietnam, the Philippines, and Thailand (see Figure 3).

Despite the growth in each country’s immigrant numbers, foreign residents make up only about two to four percent of the total population in each country, which is considerably smaller than the average of eight to ten percent in Europe. Although they face labor shortages and demographic deficits, Japan, South Korea, and Taiwan stand out among the world’s liberal democracies for their restrictive labor migration policies and low levels of international migration.

Intertwined Migration Histories

Japan, Korea, and Taiwan have a shared history of migration due to intraregional trade, imperialism, and war. Japan’s colonization of neighboring Korea (1910-1945) and Taiwan (1895-1945) generated large-scale migration from the colonies to the Japanese metropole, (present-day) Manchuria, and the maritime territory (Primorsky Krai) in the Russian Far East. By the end of the Pacific War (1941-1945), 15 percent of the entire Korean population was residing outside of the Korean peninsula. More than two million Korean and Taiwanese colonial subjects had migrated to the Japanese metropole alone as laborers, students, and soldiers, many through forced conscription from the 1930s.

During the process of decolonization and democratic reconstruction under the American Occupation (1945-1952), postwar Japan’s migration policies were focused on two goals: 1) repatriating colonial-era migrants from the metropole to the former colonies and 2) closing the shrunken post-imperial state’s borders to new immigration and return migration of former Korean repatriates. The repatriation program in the early years of the Occupation succeeded in returning approximately two-thirds of colonial-era migrants from the metropole to the Korean peninsula and Taiwan. Pursuing the second goal encompassed multiple policies that would make Japan’s citizenship and immigration laws among the most exclusionary of liberal democracies today.

In contrast to post-imperial European states that opened their borders to former colonial subjects and affirmed their rights to citizenship during the process of decolonization, post-imperial Japan reclassified former colonial subjects as aliens, extended the principle of patrilineal jus sanguinis (citizenship by descent) to citizenship attribution policies, and tightened the country’s border controls through the promulgation of the 1951 Immigration Control Law, which was modeled after the 1924 U.S. Johnson-Reed Immigration Act that set specific quotas based on country of origin. The basic provisions of Japan’s 1950 Nationality Act and 1951 Immigration Control Law remained unchanged until 1984, when the former was amended to eliminate gender discrimination in citizenship attribution (while retaining jus sanguinis), and 1990, when the latter was revised to reorganize and expand visa categories from 18 to 27 (discussed further below). Until the mid-2000s, Korean and Taiwanese colonial-era migrants and their descendants remained the largest foreign communities in Japan by far.

Post-colonial South Korea’s migration policies, meanwhile, were aimed primarily at emigration until the 1990s. With the repatriation of more than 1.5 million Koreans to the Korean peninsula after Japan’s defeat in the Pacific War and thousands of refugees from the division of the Korean peninsula in 1945 and outbreak of the Korean War (1950-1953), South Korea sought to control its overflowing population problem through migration policies that sent thousands of students, nurses, and migrant workers to Japan, Germany, Australia, the Middle East, and the Americas from the 1960s to 1980s. The only significant in-migration into South Korea until the 1990s came from North Korea, but because South Korea officially regards North Korea as part of its territory, North Korean migrants are not classified as immigrants.

Of the three East Asian cases, Taiwan stands out for its official narrative as a “country of immigration.” More than 80 percent of the current population is composed of native Taiwanese and Hakka who are descendants of immigrants from Fujian and Guangdong provinces during the 14th to 17th centuries. The minority mainland Chinese migrated to Taiwan following the island's return to China in 1945. Despite a travel ban imposed by the ruling Kuomintang (KMT) party that was not lifted until the late 1970s, emigration from Taiwan to North America, Australia, New Zealand, and other parts of Asia (especially to Southeast Asia and mainland China from the early 1990s) dwarfed immigration into Taiwan until the early 2000s.

From Closed Borders to Multi-Tier Migration Regimes

While each country’s history of capitalist development is rooted in Japan’s imperialist expansion, they each underwent rapid economic growth from the 1960s to the 1990s. Despite labor shortages, Japan, South Korea, and Taiwan kept their borders closed and, instead, tapped domestic sources of underutilized labor such as women and rural workers. By the late 1980s, as massive rural-to-urban migration and growing numbers of women entering the labor force depleted these reserve sources of labor, companies in the manufacturing, production, and service industries were routinely recruiting unregulated foreign labor—migrant workers who entered the country with tourist visas and overstayed their visas—with the tacit consent of government officials.

With plummeting fertility rates, rapidly aging populations, mounting labor shortages, and growing populations of undocumented international migrants, the three East Asian countries could no longer afford to keep their borders closed to migrant workers. Taiwan was the first to establish a formal guest worker program with the passage of the 1991 Employment Services Act. Modeled after Singapore’s system, this program allowed companies to recruit migrant workers in construction, manufacturing, and domestic care for up to three years. With the implementation of the “Go South” program the following year, which encouraged companies to recruit labor and relocate their businesses in Southeast Asia, Taiwan became a major hub for migrant workers from Indonesia, the Philippines, and Vietnam.

Japan and South Korea, meanwhile, maintained official closed-door policies to unskilled foreign workers but met labor demands through skills-training programs and diaspora engagement policies. Japan first established an “industrial trainee” program in 1981 that placed migrants from other Asian countries, mostly China, South Korea, and Vietnam, in Japanese companies for one year (with visas renewable for a maximum of three years contingent on a valid employment contract) to acquire technical skills. Given their concentration in manufacturing and construction industries, this program provided employers a legal channel to recruit cheap temporary labor for so-called 3D (dirty, difficult, and dangerous) jobs where industrial accidents were comparetively common. South Korea followed suit in 1991. Because “trainees” were not classified as “workers” protected by labor laws, they were vulnerable to employer abuse such as contract violations and unpaid wages.

The 1990 revision to Japan’s Immigration Control and Refugee Recognition Act introduced a new visa category specifically for co-ethnic immigrants that allowed for unrestricted entrance and employment rights as well as paths to permanent settlement. Although the stated purpose of the long-term residency (teijū) visa for ethnic Japanese (or Nikkei) immigrants was cultural engagement for Japan’s diaspora, the vast majority of those who entered Japan with the visa were Brazilians and Peruvians of Japanese descent recruited to work in the construction and manufacturing sectors. South Korea’s policies for recruiting co-ethnic immigrant labor were more direct than those of Japan: the largest quotas within the industrial trainee program (and, later, the official guest worker program) were reserved for co-ethnic immigrants, the overwhelming majority from China. Both sets of diaspora engagement policies generated a relatively ample pool of migrant workers within the confines of official closed-door immigration policies.

Japan and South Korea’s industrial trainee systems were plagued by exploitative practices, human rights violations, and growing populations of undocumented migrant workers. In South Korea, civil society actors who had been central to the country’s democratization movement through the late 1980s—including labor activists, religious leaders, human rights lawyers, women’s organizations, and other citizen groups—established themselves as pro-migrant advocates. With unprecedented access to the upper echelons of two progressive administrations under presidents Kim Dae Jung (1998-2003) and Roh Moo Hyun (2003-2008), the migrant rights movement succeeded in legalizing the status of migrant workers through the establishment of the Employment Permit System (EPS) in 2004, which was South Korea’s first formal foreign worker program that not only regularized migrant labor but guaranteed equal labor rights and protections. South Korea subsequently abolished the industrial trainee system in 2007.

Interner Link: Japan, by contrast, made incremental reforms to the industrial trainee system by extending the length of trainee visas and affirming labor protections and rights, leading to the establishment of the Technical Intern and Training Program (TITP) in 1993 that remains the primary unofficial pathway for recruiting unskilled and semi-skilled foreign labor. Although Japan eventually launched a formal foreign worker (“specified skilled worker”) program in 2019 to recruit skilled and semi-skilled migrant labor in agriculture, construction, shipbuilding, hospitality, and nursing, it has been accompanied by the expansion, and not the dissolution, of the industrial trainee program.

Another migration stream that South Korea and Taiwan have prioritized is in the area of what is popularly referred to as “marriage migration.” Foreign spouses of native citizens have made up one of the fastest-growing immigrant groups in Japan, South Korea, and Taiwan since the late 1990s. Local government officials in rural areas, along with agricultural associations and private brokers, began brokering arranged marriage meetings between unmarried (and often aging) farmers in their districts and foreign women from the 1980s in Japan and the 1990s in South Korea. In Taiwan, government officials were not directly involved in recruiting migrant spouses, which was managed by professional organizations both within Taiwan and in the sending countries, but the growth in “marriage migration” coincided with the promulgation of the 1992 “Go South” policy. South Korea and Taiwan have additionally invested heavily in social integration programs specifically for migrant spouses and their families that range from (Chinese and Korean) language and culture classes to employment training to crisis hotlines and shelters. In South Korea, migrant spouses also featured centrally in debates leading to the passage of an unprecedented multiple nationality bill in 2010.

Rather than a single path toward more open or closed immigration policies, Japan, South Korea, and Taiwan have adopted multiple tracks for different migrant subpopulations while maintaining relatively closed borders. As all three countries face the triple challenges of rapidly aging populations, low fertility rates, and shrinking working-age populations, we can expect the expansion of their multi-tier migration regimes that extend generous institutionalized rights for some categories of migrants and exclude others from permanent settlement.