International Journal of Sociology and Social Policy

Emerald Article: Civil society as a contested field of meanings Sandrine Roginsky, Sally Shortall

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Civil society as a contested field of meanings

Sandrine Roginsky
CELSA-PARIS IV Sorbonne, Paris, France, and

Civil society as a contested field of meanings 473

Sally Shortall
School of Sociology, Social Policy and Social Work, Queens University Belfast, Belfast, UK
Abstract
Purpose During recent years, the concept of civil society, particularly global civil society, has come to the fore in both academia and policy circles. A key component of recent theoretical and policy research is the attempt to do international comparative research on the meaning of civil society. The purpose of this paper is to argue that the language and the terminology used to describe the agents of civil society are reflective of cultural and historical contexts of societies, have distinct meanings and cannot be used interchangeably. Design/methodology/approach In different national contexts, the key agents of civil society are referred to differently; nonprofit sector, voluntary and community sector, third sector and social economy. In comparative studies, scholars often list these concepts to indicate that they recognise that the agents of civil society are referred to differently in different societies. The article offers a socio-historical analysis of each concept. It is concluded that teasing out the differences, as well as the similarities, between the nonprofit sector, voluntary and community sector, third sector and social economy, is crucial to robust comparative research on civil society. Findings This paper exposes a number of limitations of each of the terminologies used to describe civil society. They all present a much more limiting notion of civil society than that proposed by the founding fathers. None seem to capture the range of civil associations in any society. Yet, assumptions are made that the terminologies used have similar meanings rather than attempting to clarify and define exactly what is being written or described. This is exacerbated by the interchangeable usage of nonprofit/third sector/community and voluntary sector/social economy. In order to progress beyond culturally specific understandings of civil society, it is necessary to examine the terminology used and how it emanates from a specific cultural and political context. Having a clear understanding of the language used and what it signifies is crucial to robust cross-national comparative research. Originality/value This paper examines context specific understandings of civil society and the terminology used to define it; a question not previously addressed. It is hoped that this article will generate much needed further debate on cross-national meanings of civil society. Keywords Citizenship, Citizen participation, National cultures, Society, Language Paper type Research paper

Introduction Sociology is by definition comparative, as its mission is to identify social patterns, or social phenomena that are held in some way to be typical. Where sociological analysis states that it is comparative, it usually refers to the study of social patterns across nation-states (Smelser, 1976). The theoretical, methodological, and analytical difficulties posed by cross-national research were recognised by early sociologists, notably Durkheim and Weber, and contemporary sociologists continue to grapple with developing robust comparative research. Definition lies at the heart of all social analysis. Without an agreed set of concepts to give some order to reality, there is no way to group perceptions and begin making sense of them. Definitions and classifications are crucial to clear thinking and careful analysis. Such definitional development and improvement in the basic technology of thinking is an absolute

International Journal of Sociology and Social Policy Vol. 29 Nos. 9/10, 2009 pp. 473-487 # Emerald Group Publishing Limited 0144-333X DOI 10.1108/01443330910986261

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prerequisite to even the most rudimentary understanding (Salamon and Anheier, 1997). This is particularly true in cross-national settings, where common language and common cultural understandings are not available to help structure perceptions. The central objective of this article is to contribute to the development of robust crossnational comparison of civil society by demonstrating the differences between the often used interchangeably theoretical concepts: nonprofit sector, third sector, voluntary and community sector and social economy. Each concept refers to agents in civil society in a particular national context. However, the terms are not synonyms. Civil society is not a new concept and it was first coined by Adam Ferguson (1767). The concept evolved in tandem with the nation-state and the market (Bartelson, 2006). While the concept of civil society remains contested after 240 years, it is generally seen as distinctive from the political state and the economic market. Following on from Ferguson and de Tocqueville, civil society is seen as voluntaristic associationalism, where peoples relations are driven by democratic discourse, solidarity, civility, honesty, and mutual respect (Alexander, 2006; Morris, 2007). Ferguson understood civil society to upholding moral values with the advent of commercial interests (Kettler, 2005), and similarly Oakeshott (1990) describes civil association or civitas as moral association. It is distinct from the state and the market. Yet this distinction is no longer so clear. Anheier (2002) argues that the growth in civil society is due to the significant amount of public funds made available to nonprofit, voluntary and community, and third sector organisations, all agents of civil society. He further argues that the migration of civil society into commerce should not be of too much concern (p. 2). This is a debate for another day. Of concern to us in this article is that this universal pattern of government funding of civil society organisations has led to the presumption of a global civil society which shares common characteristics cross-nationally. While this is the case to some extent, it remains that the terminology used in different national and cultural contexts have different meanings. It has long been recognised that crossnational comparative research needs to engage an interpretative approach, being mindful of linguistic and cultural factors, together with differences in research traditions and administrative structures (Hantrais, 1995). This is what we are advocating for the study of civil society. By looking at the usage of the third/voluntary/nonprofit/social economy sectors as expressions of civil society the aim is twofold. First, is to explore the implicit meanings hidden in the particular usages; second, to challenge the perceived fixity and universality of the idea implicit in each meaning. Examining the figure of speech makes it possible to analyse the usage of each term as a contextual process of interpretation, with transformative effects on the social domain it is defining. Wittgenstein observes that the usage of words gives meaning to the intuition; in other words that the speaking of language is part of an activity, or a form of life (Wittgenstein, 1997, p. 11). Each way of speaking civil society reflects then a way of distinct life and relations particular to that life. It means that the understanding of civil society is distinctly located at a particular juncture of the usage or performance of civil society. This article provides a theoretical and analytical introduction to the culturally specific concepts used to describe civil society. It is laid out as follows: it offers a deconstruction of each of the concepts; nonprofit sector, third sector, community and voluntary sector and social economy. Through this analysis, it highlights differences between American and European thought[1]. It presents the differences in the cultural and theoretical traditions each concept represents. It highlights that the concepts reflect national, historical and cultural contexts, and concludes that attempts to study a

global civil society must be mindful of the cultural differences between the concepts of third/voluntary/nonprofit/social economy sectors, and the inaccuracies of using these terms interchangeably. Nonprofit sector and the American influence Nonprofit sector is a concept that first emerged in the USA, although it now holds international currency, reflecting American dominance in civil society research. This is linked to the international profile of The Johns Hopkins Center for Civil Society Studies, one of the best funded and longest established centres for civil society studies. Its funding sources are international, enhancing its global presence, and explaining the wide adoption of nonprofit as a synonym for civil society. The nonprofit sector is defined as groups of organisations that qualify for tax exemption and for tax-deductible donations ( James, 1990, p. 21). In the nonprofit sector, organisations are not allowed to distribute their profits to their owners or staff. DiMaggio and Anheier gave a more specific determination:
. . . nonprofit organizations are those falling under section 501(c)3 of the Internal Revenue Code (a category including most nonprofit hospitals, cultural organizations, traditional charities, foundations, schools, day-care centres and foundations, among others), or the smaller, related 501(c)4 category (civic leagues and social welfare organizations, which are denied tax-deductible contributions but which may engage in some political or commercial activities from which (c)3s are barred); these do not include such mutual-benefit associations as labor unions, workers or consumers cooperatives, veterans organizations, or political parties, which the law treats separately (DiMaggio and Anheier, 1990, p. 138).

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A similar definition was formulated by Salamon and Anheier (1993). According to the authors, the nonprofit sector includes all entities that are formal organisations having an institutionalised character; constitutionally independent of the state and selfgoverning; nonprofit-distributing; and involving some degree of volunteerism (Salamon and Anheier, 1993, p. 537). The comparative nonprofit sector project directed by Salamon and Anheier made a major contribution towards the development of a common definition for civil society. This definition dominates international discussions. The Johns Hopkins Comparative Nonprofit Sector Project ( JHCNSP) was launched in 1990 among 12 countries[2] to inquire into the scope, structure, history, legal position and role of the nonprofit sector in a broad cross-section of nations (Salamon and Anheier, 1997, p. xi). In order to facilitate comparative analysis, the first task of the project was to formulate a common language and concept of the nonprofit sector (Salamon and Anheier, 1997, p. 4). The JHCNSP represents a comprehensive attempt by contemporary social scientists to define civil society as occupying a distinctive social space outside of both the market and the State (Salamon and Anheier, 1997, p. 1). If the State (public) is the first sector, the market (private) the second, the nonprofit is the third sector or civil society. The project developed a structural-operational definition of the nonprofit sector. Five key structural and operational characteristics define the range of entities most commonly associated with the nonprofit sector. To be included in the sector, an entity has to be: organised or formal (i.e. institutionalised to some extent), private (i.e. institutionally separate from government), nonprofit distributing (i.e. distinguished from the market), self-governing/independent (i.e. not controlled by an outside force such as the state), voluntary (i.e. involving some meaningful degree of voluntary participation). While this is the definition for the nonprofit sector, it is worth noting

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that the term nonprofit sector is used interchangeably with the third sector, the voluntary sector, and even civil society. The JHCNSP also created a methodology for the international comparison of the nonprofit sector, stressing economic aspects. The focus is on three themes: employment and volunteering, expenditures, and financing. The data collected by the Project are useful in broadly identifying the considerable scale and significance of the sector. However, it is narrow and culturally specific in focus, overlooking much of what, for instance, in the European Union (EU) is understood to be the third sector and civil society. It is to these limitations that we now turn. Historical data have been used to demonstrate the contextual specificity of the definition of the nonprofit sector and indicate some of the weaknesses inherent in attempting to test theories of the sector with data compiled using the structuraloperational definition (Morris, 2000). While the definition proposed by Salamon and Anheier aims to be internationally useful and relevant, other scholars argue that the definition is neither universal, nor accurate in its theoretical inclusions and exclusions (Evers and Laville, 2004). The John Hopkins definition is based on the criterion of nonredistribution, underlying the American configuration of the sector, along with a significant role for foundations. This criterion does not take into account the specific legal requirements of European countries for which the distinguishing criterion is the existence of limits on redistribution (Laville et al., 1999). Indeed, in the criterion of nonprofit distribution lie the widest diversities between the American and European thinking. In Europe the main criterion is not whether the profits are distributed to owners or not but whether the general purpose of an organisation is to work on a commercial basis or not. The distinctive feature of the European approach is the attention given to the historical dynamic perspective (Laville et al., 1999). The American approach, manifested in the Johns Hopkins Project, focuses on defining the main national components of a sector comprising a community of nonprofit organisations. In contrast, the European approach, while not discarding the synthetic dimension, takes a more analytical perspective, focusing on generating voluntary association typologies that stress different modes of action and the changes in them over time.
Above and beyond this original research hypothesis, the European definition is broader because the exclusion by Johns Hopkins of co-operatives and mutual aid societies on the grounds that they can distribute some of their profits to members cannot be justified in a European context (Laville et al., 1999).

The third sector concept is a broader one in Europe, and the organisations involved are seen as part of the social economy rather than the nonprofit sector (Defourny and Develtere, 1999).
Dissimilar though they may be, the European experiences nevertheless have one thing in common: they represent a tradition that is different from the American tradition, an attempt to establish reform economies including not only forms of charity and voluntary service but also collective action based on mutual aid and the participation of socially committed citizens (Laville et al., 1999).

European research has tended to concentrate on the themes of the welfare State and the rights of citizens. To paraphrase what Taylor notes about the attitude of voluntary organisations, scholars consider the individual not only as a consumer but as a citizen (Taylor, 1992, p. 162). In the European approach, choices between sectors have not been primarily market choices but rather they have been political (Muukkonen,

2000). Such a perspective automatically introduces various concepts such as charity organisations, social movements, and the social economy. The American definition of the nonprofit sector reflects core cultural components of American culture. The American creed includes equality as one of its basic values, but this is understood as equality of opportunity rather than outcome. At the very core of American identity is a deep commitment to individualism and the individuals opportunity (and obligation) to succeed. American identity is also rooted in distinct ethnic traditions, predominantly the Protestant traditions of Americas British settlers, and this has been important in shaping American culture (Lipset, 1997). The Protestant work ethic is part of this culture. Fukuyama (2007) argues that Americans work harder than Europeans, and tend to believe in a similar fashion to the Weberian interpretation of Protestantism, that dignity lies in morally redeeming work rather than in the solidarity of a welfare state (Fukuyama, 2007, p. 3). The emphasis on individuality rather than the solidarity of a welfare state is the exact antithesis of the European model, as suggested in the varieties of capitalism literature (Hall and Lindholm, 2001). This leads to economic conceptions of citizenship based on work (Katz, 2001). To belong, one must be worthy i.e. economically productive (Shortall and Warner, 2007). The dominance of the term nonprofit as the definition of civil society is reflective of the American creed. Thus, it can be argued that the dominant American theory of the nonprofit sector presents a culturally specific and narrow definition of civil society, and limits crossnational comparative research to a search for the American nonprofit sector in other countries. The European context European research on civil society has also risen to the fore over the last couple of decades, although there are differences across Europe in how the concept is approached. While not as high-profile as the Johns Hopkins Project, some collaborative research networks have developed across Europe. Probably the best known is the EMES. It is a research network of established university research centres and individual researchers whose goal is to gradually build up a European corpus of theoretical and empirical knowledge, pluralistic in disciplines and methodology, around Third Sector issues[3]. This network exists since 1996, when an international group of scholars formed a research network that was sponsored by the EU. Having reached an unusual level of mutual understanding, trust and a common perspective of working together, a community of researchers sprang off from this working experience[4]. The network is also developing an ongoing dialogue with researchers working in similar areas in North America and other regions of the world. Thus, EMES organised the first European conference on the third sector in 2005 in collaboration with the International Society for Third-Sector Research (ISTR) which is an international network created by Salamon and Anheier. ISTR network is located in Baltimore, where the Johns Hopkins Project originated. Founded in 1992, ISTR promotes research and education in the field of civil society, philanthropy and the nonprofit sector[5]. The vocabulary here indicates the American perspective that other scholars have pointed out. However, it has to be said that ISTR played and still does a crucial role in expanding and stimulating the development of third sector research. Further, it should be noted that the European ISTR Regional network is located in England, in the Charities Aid Foundation. EMES, on the other hand, is located in Brussels. It actually seems to be more of a Continental and Northern

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Europe network, as the founding members (as well as current individual members) seem to be mostly from Germany and France, as well as Norway, Denmark, Finland, Sweden and recently Poland. Alongside these two European networks, there is a third significant network. The Third Sector European Policy network, which focuses on narrower issues (such as the European third sector policy) originated in the Centre for Civil Society of the London School of Economics (LSE). In 2002, Jeremy Kendall secured funding with research partners from eight other European partners to initiate comparative empirical work on third sector European policy under the European Commissions 5th framework. The focus of the project developed out of work by Kendall and Anheier at the Centre for Civil Society on the policy analysis of the role of the third sector in EU policy making. There are, however, cultural differences in the terminology referring to civil society across Europe. It is to these concepts that we now turn. The third sector The third sector is a term for civil society that has much greater currency in Europe than the USA, particularly in France and Southern Europe. The contemporary revisiting of civil society began with the work of Etzioni and Levitt in 1973. Etzioni referred to the trichotomy of State, market and the third sector, although the latter was initially referred to as the public sector. For Etzioni, the public sector is everything that is not purely governmental or profit oriented (1973, p. 316). Etzioni includes (or at least does not exclude) informal networks and families in the third sector. Etzionis definition provided an important starting point for current debates:
It is wide enough that it does not accidentally exclude some interesting phenomena, but it is so wide that it has not been used much in third sector studies (Muukkonen, 2000).

According to Defourny et al. (2000), of all designations employed to describe the activities that do not fit the classical categories, third sector is without doubt the expression over which there is the widest international agreement among researchers. However, Mertens points out that
The concept of the third sector generally held in French-speaking cultures [and] needs to be appreciated within the context of an environment conditioned by State interventionism and by the existence of already long-standing communal organisations. In France and Belgium the welfare State does indeed provide and performs by itself a good deal of those activities that are entrusted to the third sector in [Anglo-Saxon traditions] (Mertens, 1999, p. 516).

Former European Commission President Jacques Delors introduced the concept third sector at the end of the 1970s. He published an article Pour la creation dun ` troisieme secteur (For the creation of a third sector) in which he analysed the emergence in the 1970s of a large number of initiatives by young men and women who wanted to start up new activities and were looking for other legal frameworks than those available at the time (such as cooperatives, associations and of course the privatesector profit-making companies) (Delors and Gaudin, 1979). He built on the report to call for the establishment of a legal and financial framework that could promote the development of such initiatives and the creation of employment. The debate moved on in the late 1990s with the publication of Lipietzs report into the third sector. The third sector was the term used to describe all socio-economic activities not part of either the market or State arenas, or which also have a dimension of social, environmental or cultural utility. The third sector was to be a space, identified by a common label,

essentially encompassing the social and solidarity-based economy as currently understood, but with a possible extension into the private sector (Lipietz, 2001). Evers and Laville (2004) argue that the term third sector is often used because it appears as a neutral term, free of an a priori link with any theoretical or ideological tradition. This, however, implies that the same word, third sector, can have different meanings. Consequently, there are a number of interpretations of the third sector that enjoy a level of currency at the European level. The first is that of a third sector perceived as not-for-profit sector or services of general interest. The second is of organisations which present themselves as advocacy groups in the process of European civil dialogue. The risk of this approach is that it underestimates the economic dimension of the third sector and denies it a voice within European social dialogue (Fraisse, 2002). The third concept is of social enterprise, seen as one of the four entrepreneurial models within Europe: for-profit enterprises, public enterprises, family enterprises and social enterprises (Fraisse, 2002). At a research level, the term third sector reminds us that third sector organisations do not operate in isolation (Mertens, 1999). However this can be challenged (CurrySmithson, 1995). At least in historical or evolutionary perspective this sector could be considered as first, or prior to either State or market. Others point out that third sector is principally the vocabulary of political scientists, several of whom have read too many economists (Thayer Scott, 1999), meaning here that the economic approach is still very much dominant in the term third sector. Indeed, it seems that, for most French thinkers, the sector can be considered as a sphere of economic activities that occupies the space between the point where the private sector ends and the point where the State sector begins (Landeau, 1995). Again, the development of this concept is culturally specific. In France, civil society was viewed with suspicion as interference in the relationship between the citizen and the state. It seems appropriate then that the state introduced the concept of the third sector as the synonym for civil society. The voluntary and community sector Karl (1984) argues that the etymon voluntary refers originally to religious concerns. From there it spread to military service and agriculture. He also notes that an important controversy has always been present in discussions of the volunteer, namely whether volunteers are better at their duties than professionals. In the modern usage the term has two connotations (Muukkonen, 2000). First, the main reference is to volunteering as a phenomenon in different organisations. In this sense it distinguishes itself from professionalism, but it does not identify the kind of organisations in which volunteering occurs. Second, the term refers to the character of the organisations. Voluntary organisations are formed freely to satisfy the needs of people. While the concept of a voluntary sector seems easy to identify in the UK, it is much more difficult to recognise elsewhere. It is worthy of note that the Centre for Civil Society in the LSE was previously the Centre for Voluntary Organisation. The voluntary sector in the UK has its roots in the philanthropic organisations that developed with industrialisation. While economic success at this time was seen as an expression of God, visible displays of wealth were not, and a philanthropic culture of contributing to charitable foundations and undertaking programmes of social reform developed. Leat (1997) criticises the implicit assumption in the definition and promotion of voluntary sector that this is a discrete sector which contributes particular characteristics to the welfare mix flexibility, closeness to the customer and so on, while

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larger organisations in the voluntary sector can lay less claim to these attributes. Taylor (2004, p. 124) stresses that their critique is reflected in the increasingly common use of the phrase voluntary and community sector to describe the sector in the UK. Taylor explains that this distinction has been promoted by a Community Sector Coalition, set up to ensure that the interests of smaller, more associational organisations are not crowded out by those of larger, more professionalised and formally organised nonprofit organisations (Taylor, 2004, p. 125). Consequently, the term voluntary sector includes, or sits alongside, the community sector. Reference to the voluntary sector generally means both the voluntary and community sectors. In both cases, it usually means service delivery organisations. However, the term community itself is not without problems, as it is often based on unarticulated assumptions and can carry a range of meanings (Kenny, 1999, p. 7). Thus, the elasticity of the concept of community allows diverse intellectual and political traditions to lay claim to it as a unifying symbol (Powell and Geoghegan, 2005, p. 139). As Schuler (1996, pp. 2-3) stresses, the term community can be used in various ways: it can refer to a group of people living in a contiguous geographical area; it can identify a group of like-minded individuals; or it can refer to a sense of community that individuals in a group feel when they belong to a greater social unity. Communities are social constructs which tend to change over time and space. According to Hughes and Mooney (1998, p. 72), communities are always imagined. The nation, for instance, has been imagined as a community with a limited membership and based on a deep horizontal comradeship, binding together people who do not know each other and who will never meet (Anderson, 1991, pp. 6-7). Whatever the scale and the nature of the community, it usually implies a sense of common identity. This identity may be based on shared class, geographical location, cultural values, gender, race, ethnicity, disability, workplace or age, or it may be selfdefined on the basis of similar political or other special interests (Kenny, 1999, p. 38). While the concept of the third sector emphasises the notion of structure, the voluntary sector concept focuses more on the notion of practice (Simonet, 1998, p. 58). The community sector tends to emphasise the notion of identity, and to a certain extent place and location. Further, regarding the meanings of the voluntary sector, it is important to note that it is also possible to find voluntary action within public/State administrations, such as public or private hospitals. Besides, scholars such as Perri and Leat differentiate between the invention of a sector [and] a looser, earlier definition of voluntary action as a style or principle (Perri and Leat, 1997). According to Whelan (2000, p. 10), the voluntary sector is part of what the economist Friedrich Hayek described as the third sector, distinct from the State on the one hand and the commercial sector on the other. However, through volunteerism in State organisations, the concept of the voluntary sector expands itself to the sphere of the State and, therefore, differs from the other concepts. Both the concepts of voluntary sector and third sector reflect contrasting traditions and understanding of the welfare State, society, solidarity, and citizenship in Europe. The concept of voluntary sector held in Anglo-Saxon countries (Simonet, 1998, p. 57) is associated with a liberal vision of society, under which individual rights and benefits are emphasised as a means to personal autonomy. The notion of the third sector seems to emanate from a Continental tradition, and particularly a French one, where the idea of one indivisible Republic emphasises the third sector as a part of a whole society and suggests that the associative sector, as the third sector is also called in France, is a social agent and a means to ensure social inclusion (Simonet, 1998).

The social economy While the term social economy originated in Europe, it later emerged in North America, particularly in Canada and Quebec with its ties to the UK and France as well as other European countries, especially Germany and Belgium (Laville et al., 2005b). The term social economy first appeared in France during the first third of the nineteenth century. The concept of social economy was brought to the fore in the nineteenth century by French-speaking economists Gide and Walras (Fraisse, 2002) who wanted to reinvent economics to centre on new fundamentals (Bidet, 2000). At that time, the social economy was defined as a new scientific discipline whose purpose and methodology were complementary and distinct from political economics or pure economics.
The idea of social economy covered a much wider area than today, although cooperatives, mutual benefit societies and nonprofit organizations already occupied a central position (Defourny, 1992, p. 27).

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For a long time, its meaning was much broader and amorphous than it is today. However, along with the parting of these movements (cooperatives, mutual societies, associations) the importance of the concept diminished. The concept of social economy was adopted again in the 1970s when these movements became close to each other. No longer describing an academic discipline, it is now used to identify forms of economic organisation in which mutual societies, cooperatives, and associations, notwithstanding their differences, can all find common identity and aims. The concept of social economy refers to organised activities which aim at serving the community, are being built on democratic values, and are organisationally independent of the public sector. These social and economic activities are run mainly by associations, cooperatives, foundations and similar groups. The main driving force of the social economy is the benefit of the public or the members of a particular association, and not the profit motive. According to Veron (1995, p. 35, in Muukkonen, 2000), the main characteristics of social economy organisations are independence from the State; one man one vote principle; and the social nature of the activities. Moreover, these organisations hold values like the right to associate, democratic control, solidarity, justice and equal opportunities (Muukkonen, 2000). Defourny adds the absence of a profit motive, freedom of membership, democratic management and independence from public authorities (Defourny, 1992, p. 36). According to him, social economy is a synonym for the economics of social matter (1992, p. 36). Defourny also refers to Desroches suggestion that social economy has some common ground with its four boundaries, with which it interacts: public sector, local public sector, private sector and trade union sector (Defourny, 1992, p. 37). According to Van Til (1988), the concept of social economy represents the unique combination of purpose and organisation involved in effective voluntarism. This concept draws fully on the democratic theories of populism, idealism, pluralism and social democracy. It clarifies a position for voluntary organisations in society, and it suggests a variety of productive roles for individuals, both inside and outside formal organisations. Thus, Defourny et al. (1999) explain:
Anyone can develop their own a priori conception of the social economy, simply by placing more or less emphasis on either its economic or its social dimensions, both of which are wideranging. In the final analysis, any economic phenomenon that has a social dimension, and any

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In the EU, the concept of social economy challenges the American concept of nonprofit sector and the British/Irish concept of voluntary (and community) sector. Social economy was adopted as an official EU term in 1989. Helander (1998) believes that this might lead to reformulation of the whole third sector concept (Helander, 1998, in Muukkonen, 2000). However, Fraisse (2002) notes that despite the lobbying effort, the European Commission does not always use the term social economy, talking instead of the third sector, third system, or civil society. Although the notion of the social economy is relatively widespread in Southern Europe (France, Spain, Italy, Portugal, Greece) and Belgium, it is little used, even sometimes avoided, in the UK, Germany, Scandinavian countries, and Eastern Europe (Fraisse, 2002). Some conclusions The idea of civil society as a sphere of social life separate from the State took shape in the late eighteenth and early nineteenth centuries. As it did so, it took different forms (Seligman, 1992, pp. 10-11) and we argue that these are still visible in the more contemporary language that has emerged to describe civil society. One tradition reflected the French revolution, found in the work of Frederich Hegel which viewed civil society in a generally unfavourable light, seeing it as an interference between the citizen and the state. The other is the Anglo-American conception, which views civil society as the ultimate repository of individual rights and liberties that must be protected against incursions by the State. In the latter school of thought, civil society is seen as a selfregulating universe of associations committed to provide a buffer against undue intrusion by the State into the life of the individual (Nisbet, 1962). When the term civil society came into popular usage in the 1970s and 1980s, it reflected these earlier traditions. Contemporary American political theories are rooted in an economic understanding of civil society, and the nonprofit sector is the dominant terminology. European approaches on the other hand include a social-political dimension. European theories tend to be embedded in theories of citizenship and the welfare State (Wuukkonen, 2000). Therefore, we argue that not only is civil society framed differently in different research traditions, but culture and national history also frame this singular social space differently. Thus, the country of origin has as much influence in the development of the various concepts of this arena as has the academic discipline or the availability of data on the subject. This article exposes a number of limitations of each of the terminologies used to describe civil society. They all present a much more limiting notion of civil society than that proposed by the founding fathers. None seem to capture the range of civil associations in any society. Yet, assumptions are made that the terminologies used have similar meanings rather than attempting to clarify and define exactly what is being written or described (Deakin, 2000). This is exacerbated by the interchangeable usage of nonprofit/third sector/community and voluntary sector/social economy. In order to progress beyond culturally specific understandings of civil society, it is necessary to examine the terminology used and how it emanates from a specific cultural and political context. Having a clear understanding of the language used and what it signifies is crucial to robust cross-national comparative research. This article examines context specific understandings of civil society and the terminology used to define it; a question not previously addressed. It is hoped that this article will generate much needed further debate on cross-national meanings of civil society.

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Giddens, A. (1998), The Third Way, Polity Press, Cambridge. Gordenker, L. and Weiss, T.G. (1995), Pluralizing global governance: analytical approaches and dimensions, Third World Quarterly, Vol. 16 No. 3, pp. 357-87. Hall, P.D. (1992), Inventing the Nonprofit Sector and Essays on Philanthropy, Voluntarism, and Nonprofit Organizations, Johns Hopkins University Press, Baltimore, MD.

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Hirst, P. (1994), Associative Democracy New Forms of Economy and Social Governance, Polity Press, Cambridge. James, E. (1987), The nonprofit sector in comparative perspective, in Powell, W.W. (Ed.), The Nonprofit Sector: A Research Handbook, Yale University Press, New Haven, CT, pp. 397-415. Kendall, J. and Almond, S. (1999), United Kingdom, in Salamon, L., Anheier, H.K., List, R., Toepler, S., Sokolowski, S.W. and Associates (Eds), Global Civil Society Dimensions of the Nonprofit Sector, The Johns Hopkins Comparative Nonprofit Sector, Baltimore, MD, pp. 179-97. Kendall, J. and Knapp (1995), A loose and baggy monster: boundaries, definitions and typologies, in Smith, J.D., Rochester, C. and Hedley, R. (Eds), An Introduction to the Voluntary Sector, Routledge, London, pp. 66-95. Laville, J.-L., Magnen, J.-P., Franca Filho, G.C. and Medeiros, A. (2005a), Action Publique et Economie Solidaire Une Perspective Internationale, Edition Eres, Toulouse. Levitas, R. (1998), Community rules, in Levitas, R. (Ed.), The Inclusive Society? Social Exclusion and New Labour, MacMillan Press, London. Lewis, D. (1998), Bridging the gap?: The parallel universes of the nonprofit and nongovernmental organisation research traditions and the changing context of voluntary action, CVO International working paper, School of Economics and Political Sciences, Centre for Civil Society, London, available at: www.lse.ac.uk/Depts/ccs/pdf/int-workpaper1.pdf Milofsky, C. (1987), Neighborhood-based organizations: a market analogy?, in Powell, W.W. (Ed.), The Nonprofit Sector: A Research Handbook, Yale University Press, New Haven, CT, pp. 277-95. Perru, O. (2000), Pour une epistemologie du concept dassociation chez Emile Dukheim et chez Max Weber, Philosophiques, Automne, Vol. 27 No. 2, pp. 351-76, available at: www.erudit.org/revue/philoso/2000/v27/n2/004966ar.pdf Reed, P.B. and Howe, V.J. (1999), Defining and classifying the nonprofit sector, Research Paper, Notes Prepared for the Advisory Group on Nonprofit Sector Research and Statistics, Statistics Canada, Ottawa. Reimer, S. (2005), Civil society and its measurement in an international research project: methodological issues emanating from the conducted German analysis, paper presented at the First European Conference of EMES and ISTR, France, available at: www.cridafr.org/03_actualites/streams/M%20-%20ISTR-EMES%20Reimer.doc Salamon, L. and Anheier, H.A. (1992), In Search of the nonprofit sector I: the problem of classification, Working papers of the Johns Hopkins Comparative Nonprofit Sector Project, The Johns Hopkins Center for Civil Society Studies, Baltimore, MD. Salamon, L. and Anheier, H.K. (1996), The Emerging Nonprofit Sector: An Overview, Manchester University Press, Manchester. Salamon, L. and Anheier, H.K. (1992a), In search of the nonprofit sector I: the question of definitions, Voluntas: International Journal of Voluntary and Nonprofit Organizations, Vol. 3 No. 2, pp. 125-51.

Salamon, L. and Anheier, H.K. (1992b), In search of the nonprofit sector I: the problem of classification, Working Papers of the Johns Hopkins Comparative Nonprofit Sector Project, The Johns Hopkins Center for Civil Society Studies, Baltimore, MD. Seckinelgin, H. (2002), Civil society as a metaphor for western liberalism, Civil Society Working Paper No. 21, School of Economics and Political Sciences, Centre for Civil Society, London, available at: www.lse.ac.uk/Depts/ccs/publications/cswp/civil_society_wp.htm Seibel, W. and Anheier, H. (1990), Sociological and political sciences approaches to the third sector, in Anheier, H. and Seibel, W. (Eds), The Third Sector Comparative Studies of Nonprofit Organizations, Walter de Gruyter, Berlin/New York, NY, pp. 7-20. Siisiainen, M. (2000), Two concepts of social capital: Bourdieu vs. Putnam, Proceedings of the Fourth International Conference of the International Society for Third Sector Research (ISTR), 5-8 July, Dublin. Smith, D.H. (1997), The rest of the nonprofit sector: grassroots associations as the dark matter ignored in prevailing Flat Earth maps of the sector, Nonprofit and Voluntary Sector Quaterly, Vol. 26, pp. 114-31. Streeten, P. (1997), Nongovernmental organizations and development, Annals of the American Academy of Political and Social Science, Vol. 554, pp. 193-210. Thayer-Scott, J. (1997a), Defining the nonprofit sector, in Hirshhorn, R. (Ed.), The Emerging Sector In Search of a Framework, CPRN Study 01, Canadian Policy Research Networks, Ottawa. Thayer-Scott, J. (1997b), Whats in a name?, Canadian FundRaiser, available at: www.charityvillage.com/cv/research/rvolism2.html (accessed 4 June). Tonnies, F. (1955), Community and Association (Gemeinschaft and Gesellschaft), Routledge & Paul, London. Van Til, J.V. (2001), Building social capital and growing civil society, Monday Night Lecture Series, available at: www.pendlehill.org/von_til.htm Walzer, M. (1998), The idea of civil society: a path to social reconstruction, in Dionne, E.J. (Ed.), Community Works: The Revival of Civil Society in America, Brookings Institution, Washington, DC, pp. 123-43. Ware, A. (1989), Between Profit and State Intermediate Organizations in Britain and the United States, Polity Press, Cambridge. Wijkstrom, F. (1997), The Swedish nonprofit sector in international comparison, Annals of Public and Cooperative Economics, Vol. 68 No. 4, pp. 625-63. About the authors Sandrine Roginsky was awarded funding from the Royal Irish Academy to complete her comparative PhD thesis on the Third Sector and Social Change at Queens University Belfast, Northern Ireland. She now lives in Paris, working as a Research Fellow for the European Parliament. She also holds part-time appointments in Paris-Sorbonne University and in Paris 12 Val de Marne University. Sandrine Roginsky can be contacted at: sandrine@verts-europesinople.net Sally Shortall is a Reader of Sociology at Queens University Belfast, Northern Ireland. She has over 70 publications in rural sociology and rural social policy, and research grant earnings of over a million pounds. She is currently an ESRC Fellow in the Department of Agriculture and Rural Development Northern Ireland. Sally Shortall can be contacted at: s.shortall@qub.ac.uk

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