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

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Migration Politics in East Asia: Comparing Japan, South Korea, and Taiwan

Erin Aeran Chung

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Japan, South Korea and Taiwan stand out among liberal democracies for their restrictive labor migration policies and low levels of international migration. How do they manage migration? An overview.

A message screen seen in the national immigration agency in Taipei, December 2020. (© picture-alliance)

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).

Figure 1: Foreign Residents in Japan by Nationality 1985-2020 (Interner Link: Grafik zum Download) (© bpb)

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.

Figure 2: Foreign Residents in Korea by Nationality 2000-2020 (Interner Link: Grafik zum Download) (© bpb)

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.

Figure 3: Foreign Residents in Taiwan by Nationality 1995-2020 (Interner Link: Grafik zum Download) (© bpb)

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.

Quellen / Literatur

Cheng, Lucie. 2002. "Transnational Labor, Citizenship, and the Taiwan State." In East Asian Law: Universal Norms and Local Cultures edited by Arthur Rosett, Lucie Cheng and Margaret Woo, 85-105. London: RoutledgeCurzon.

Chung, Erin Aeran. 2010. Immigration and Citizenship in Japan. New York: Cambridge University Press.

Chung, Erin Aeran. 2020a. Immigrant Incorporation in East Asian Democracies. New York and Cambridge: Cambridge University Press.

Chung, Erin Aeran. 2020b. "Creating Hierarchies of Noncitizens: Race, Gender, and Visa Categories in South Korea." Journal of Ethnic & Migration Studies, vol. 46, no. 12: 2497-2514. doi:

Chung, Erin Aeran. 2022a. “The Developmental Migration State in East Asia.” In Understanding Global Migration, edited by James Hollifield and Neil Foley, 127-151. Palo Alto, CA: Stanford University Press.

Chung, Erin Aeran. 2022b. “The Side Doors of Immigration: Multi-Tier Migration Regimes in Japan and South Korea.” Third World Quarterly, vol. 43, no. 7 (2022): 1570-1586, DOI: 10.1080/01436597.2021.1956893.

Chung, Erin Aeran, and Daisy Kim. 2012. “Citizenship and Marriage in a Globalizing World: Multicultural Families and Monocultural Nationality Laws in Korea and Japan.” Indiana Journal of Global Legal Studies, vol. 19, no. 1: 195-219.

Kim, Jaeeun. 2016. Contested Embrace: Transborder Membership Politics in Twentieth-Century Korea. Palo Alto, CA: Stanford University Press.

Korea Immigration Service, Ministry of Justice. 2021. K.I.S. Statistics 2020 (2020 Chulipguk Oegukin Tong'gye Yonbo).

Ministry of Internal Affairs and Communications, Japan. 2021. "Japan Statistical Yearbook."

Ministry of Justice, Japan. 2021. "Reiwa 3nenmatsu genzaini okeru gaikokujin tōrokusha tōkeini tsuite" [Report on Current Foreign Resident Statistics at the End of 2021].

Ministry of Interior, Department of Household Registration Affairs, Republic of China. 2021. "Statistical Yearbook of Interior."

Morris-Suzuki, Tessa. 2010. Borderline Japan: Frontier Controls, Foreigners and the Nation in the Postwar Era. Cambridge: Cambridge University Press.

Sharpe, Michael O. 2014. Postcolonial Citizens and Ethnic Migration: The Netherlands and Japan in the Age of Globalization, Palgrave Studies in International Relations. Houndmills, Basingstoke, Hampshire: Palgrave Macmillan.

Tian, Yunchen, and Erin Aeran Chung. 2018. "Is Japan Becoming a Country of Immigration?" Foreign Affairs, Externer Link:

Tian, Yunchen. 2019. "Workers by Any Other Name: Comparing Co-Ethnics and "Interns" as Labour Migrants to Japan." Journal of Ethnic & Migration Studies, vol. 45, no. 9: 1496-1514. doi: 10.1080/1369183X.2018.1466696.

Tsuda, Takeyuki. 2003. Strangers in the Ethnic Homeland: Japanese Brazilian Return Migration in Transnational Perspective. New York: Columbia University Press.

Wang, Hong-Zen. 2011. "Immigration Trends and Policy Changes in Taiwan." Asian and Pacific Migration Journal, vol. 20, no. 2: 169-194.



  1. This essay draws on prior research published as Erin Aeran Chung (2020) Externer Link: Immigrant Incorporation in East Asian Democracies.

  2. Chung 2020a.

  3. Kim 2016.

  4. See Morris-Suzuki 2010.

  5. Chung 2010.

  6. Chung 2022a.

  7. Taiwan established a limited guest worker program in the late 1980s.

  8. Chung 2022b.

  9. Chung 2020a.

  10. Chung 2010; Tsuda 2003; Sharpe 2014; Tian 2019.

  11. See Chung 2020a.

  12. Foreign workers recruited through the EPS are issued an E-9 Nonprofessional Employment visa that limits their residency in South Korea to three years, with the possibility of a single two-year renewal. That is why they are often referred to as “guest workers” by scholars. See Chung 2020a, 2022b.

  13. See Tian 2019.

  14. See Tian and Chung 2018; Chung 2020a.

  15. See Chung 2020a.

  16. Chung 2022b.


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is the Charles D. Miller Professor of East Asian Politics and Director of Undergraduate Studies in the Department of Political Science at Johns Hopkins University, USA. Her research interests include East Asian political economy, comparative citizenship and migration politics, civil society, and comparative racial politics. She is author of Externer Link: Immigration and Citizenship in Japan (Cambridge, 2010, 2014) and Externer Link: Immigrant Incorporation in East Asian Democracies (Cambridge, 2020).