Homelessness and EU Citizenship in a Borderless Europe
This is part of our special feature, Homelessness and Poverty in Europe.
The free movement of persons, one of the flagship principles of European integration, is supposed to improve the living and working conditions and social advancement of EU citizens; however, the reality is quite different for many. Research shows that in many European cities, a significant and consistent part of the homeless population includes EU citizens from other Member States. It is estimated that in Barcelona, Spain, about a quarter of the homeless population is constituted by citizens of other Member States, while in Brussels, Belgium, that share might be closer to half of the homeless population; likewise in Copenhagen, Denmark, the great majority of rough sleepers are also citizens of other Member States. What is more, evidence collected in Brussels suggests that homeless EU citizens might be worse off in terms of actual living conditions than other groups: they sleep more often on the streets and are often denied access to social support and shelter.
Though the number of homeless EU citizens might be increasing in cities all over Europe, the issue is certainly not a new phenomenon. Before Brexit, the United Kingdom’s government tried to expel homeless EU citizens by qualifying rough sleeping as an “abuse” of free movement. In 2017, Berlin was featured in international headlines when local politicians and officials expressed their wish to expel a growing number of homeless Eastern Europeans who were living in city parks and burdening facilities. As early as 2010, local governors in the Netherlands already spoke of a “tsunami of Eastern Europeans” causing nuisance and overcrowding homeless shelters. More recently, however, an altogether new practice and discourse emerged. Today, unless EU citizens can prove permanent residence status, Dutch municipalities consider them as niet-rechthebbenden, which roughly translates to “non-rightsholders”—or “those without rights”—and refuse them access to regular homelessness services. As the Dutch government itself admitted in a recent Plan of Action, the “entire group” of homeless EU citizens carries the stigma of being “non-rightsholders who have been causing nuisance for several years.”
Institutionalized discrimination against homeless EU citizens as “non-entitled” migrants raises very serious legal, empirical, and normative questions about EU citizenship itself. After all, isn’t the presumption of “non-entitlement” that has taken hold in various Member States the very opposite of what EU citizenship has been supposed to achieve as a fundamental status offering non-discrimination on the basis of nationality? This (short) research article mainly focuses on the fundamental legal questions: what rights do homeless people derive from their status as EU citizens in Member States other than the Member States from which they originate? Under what conditions should EU Member States offer homelessness support to EU citizens, and can homeless EU citizens be expelled? Before answering these legal questions, however, the article draws on existing research to contextualize the social reality of homelessness among EU citizens and situate the phenomenon within the European integration project. After answering the legal questions, the article makes a first attempt at explaining why the institutionalized discrimination of EU citizens can persist in Member States.
Homelessness and European integration
The vast majority of EU citizens experiencing homelessness originally left their home country with the aspiration to find (better) work abroad and improve their quality of life. This fact helps us to connect homelessness to the very raison d’être of the freedom of movement principle in the European Union. Rather than an inalienable liberty, the right of freedom of movement serves a particular purpose, acting as an instrumental freedom within a European market space. It guarantees workers “the possibility of improving their living and working conditions and promoting their social advancement, while helping to satisfy the requirements of the economies of the Member States.” Successful are Adrian Favell’s “Eurostars,” “the professionals, the skilled and the educated” who build a transnational life and career in a Member State other than their own and, in the process, help to create a common European identity.
This is certainly only one side of the story: many EU citizens come to work and live on the “other side” of the labor market and society. It is via their social contacts or temporary work agencies that they move in search of work; however, upon arrival in their new destination Member State, they often find out that the promised work is short-term, informal, exploitative, or non-existent. What is more, in Member States where wages are high, entire labor-intensive industries such as agriculture, meat production, construction, distribution, and transport—whether these industries are actively encouraged or passively tolerated by the respective national or local governments—have become reliant on the “cheap” labor provided by migrant workers from Middle and Eastern Europe. In a system largely dominated by temporary work agencies, EU citizens might find themselves exploited, isolated, and severed from the social structures that are supposed to protect workers. In a context of irregular and low pay, wage deductions, life in poor, overcrowded, collective accommodations isolated from the outside world, and formal and de facto exclusions from social security and health care, the risk of becoming homeless is always around the corner for these workers. Particularly telling is the example of the Netherlands, where because of extremely flexible rules regulating temporary agency work, it is common practice that EU citizens who get sick, have an accident, or somehow cause “trouble” be immediately fired and expelled from their accommodation, making them roofless overnight.
As the pioneering ethnographic research of Magdalena Mostowska has revealed, the social pressure EU citizens feel about integrating successfully makes them reluctant to return to their Member State of origin when they become homeless. In order to avoid feeling shame, being frustrated, and having to confront families and friends, some EU citizens prefer a life on the streets in another Member State. While economic and social marginalization in their home country might have driven their decision to migrate in the first place, the act of migration reinforces this marginalization; indeed, their status as migrants makes it difficult for them to establish social networks or find professional support to escape the situation.
The Amsterdam-based organization AMOC captures what is at stake in its mission statement: “[Providing] assistance to (Eastern) Europeans: in a quest for prosperity and happiness, stranded in Amsterdam without a job and greatly lacking adequate information.” This image of the “stranded migrant” points to the shadowy side of free movement as the source of an economically instrumental migration flow: migration cannot be economically “successful” for all in a European labor market that produces its own precariat. Homelessness, in other words, is not an unfortunate coincidence at the margins of free movement in the EU, it is rather one of its (many) effects.
Homelessness, equal treatment, and expulsion
So, what about the law? EU legislation on people’s freedom of movement does not have much specific to say about the treatment of homeless people or about the organization, quality, or eligibility conditions of homelessness services in the Member States of the EU. Instead, as EU law is supreme over national laws and directly invocable by EU subjects, it operates through the rights of residence and equal treatment. Indeed, all EU citizens can rely on their constitutional right to freely move, reside, and receive equal treatment in other Member States of the Union. As the European Court of Justice decided in the case of a homeless Frenchman living in Brussels, EU citizens should be able to rely on their “fundamental status” to be protected against discrimination and expulsion. However, free movement in the EU does not (yet) guarantee “complete equality” from day one. Conditions and limitations exist, mostly to help Member States protect their public finances and social security systems. What this balance means for the legal position of homeless EU citizens depends on their individual situation.
Before turning to their substantive rights however, it is important to mention that many EU citizens already confront a wall of bureaucratic barriers when seeking a way out of homelessness. For example, in Barcelona, EU citizens have to possess a “formal registration certificate,” and in Copenhagen, they must show a “yellow card.” Authorities in Amsterdam deny homelessness support to EU citizens who are classified as “code 30” in the population registry, even though this is the standard code assigned to all EU citizens living in the country. It is legally dubious for Member States to cling to these bureaucratic formalities as a way to deny EU citizens their substantive rights. As the European Court of Justice has explained many times, EU citizens should be able to directly rely on their constitutional status to cut through the red tape in any Member State. As the Citizenship Directive clearly states: “entitlement to rights may be attested by any other means of proof.”
The (vast) majority of homeless people in the EU are EU citizens who left their Member State of origin to find work elsewhere in the Union. Hence, many have a work history and some might, in fact, still be employed in their destination country. EU law continues to reserve special treatment for EU citizens and their family members who are—or have been—workers. Having or “retaining” the status of “worker” is thus crucial: working EU citizens and their families have access to the welfare state on the same terms as national workers. In order to qualify as a “worker”—whether employed or self-employed—an EU citizen must generally be engaged in some form of economic activity that is “real and genuine.” In contrast to the opinion of some Member States’ authorities, employment does not have to be full-time or even ensure sufficient resources. According to the Court of Justice, EU citizens also qualify as workers when they work part-time or earn less than the social minimum, even when this implies that they become eligible to draw on state support. This situation means that national citizens and EU citizens who, for example, work in food delivery for a couple of days a week should have access to homelessness services on equal terms.
EU law would be meaningless if it did not protect mobile workers when they need it most, namely at the moment they lose their job, as in the previous example about the EU citizens who work under precarious arrangements for temporary work agencies in the Netherlands. EU law allows these workers to retain their crucial status as “workers” after they become jobless as well as in cases of subsequent homelessness. Those losing their job because of a temporary inability to work enjoy equal treatment under the law as regards social benefits and services until the moment they recover. Additionally, EU citizens who become involuntarily unemployed continue to enjoy this right to equal treatment for at least half a year when they register with the local employment office. It is another misconception that EU citizens without a job can simply be excluded as “jobseekers.” Although “jobseeking” EU citizens can be excluded from social assistance, the law is quite clear that this exclusion is normally limited to the period immediately after first entry, after which EU citizens are given nine months to obtain work. It seems, however, that the authorities in various Member States abuse this exception as a convenient carte blanche to also deny former workers access to social assistance and homelessness support.
Legal matters get even more complicated when the position of homeless EU citizens without a work history is considered. These so-called economically “inactive” EU citizens also enjoy the right to freedom of movement under the law. Although they are allowed to stay for three months in any Member State by simply carrying a valid ID card, if they want to stay longer they are required to be economically self-sufficient and have health insurance. This requirement is meant to prevent them from becoming an “unreasonable burden” on the social assistance system. Arguably driven by the economic crisis and the prospect of Brexit at the time, it is with respect to this category of migrants that the Court of Justice abandoned its earlier ideas about solidarity and took a more restrictive turn. In the (in)famous Dano judgment, the Court found that a Romanian mother and her young son could simply be denied social assistance because the mother did not have a job and lacked sufficient resources. The consequences have been catastrophic from a social perspective, as the judgment essentially indicated that the Court tolerated that EU citizens could live as second-class citizens with no access to social benefits. Perhaps in an attempt to counter the effect of this judgment, the Court recently invoked the fundamental right to human dignity to ensure that a Dutch mother and her two children who lived in a Northern Irish shelter after fleeing the family home because of domestic violence could live in dignified conditions.
Permanent residence, finally, could be seen as the holy grail for EU citizens in precarious conditions. This legal status grants EU citizens unconditional equal treatment—allowing them to receive social benefits and support on par with national citizens—and prevents them from being expelled. Sometimes, EU citizens requesting homelessness support have earned their permanent residence status many years prior. This status is normally acquired by EU citizens in a host Member State after they have lived there legally and continuously for a period of five years. Moreover, incapacity as a result of an accident at work immediately qualifies workers for permanent residence. For example, it is possible for a homeless Romanian citizen confined to a wheelchair to acquire permanent residence in the Netherlands without strictly meeting the five year requirement. Once acquired, permanent residence can only be lost by EU citizens by leaving the host Member State for more than two consecutive years.
Rather counterintuitively in a Europe of open borders, Member States can in fact expel EU citizens. The Netherlands, for one, makes use of this possibility and forcefully removes a couple of hundred EU citizens every year. Member States can legitimate such expulsions first on grounds of public policy or public security, invoking the safeguard of social order or the security of the state and its institutions. The threshold for this type of expulsion is high, and thus it is used restrictively. Mere convictions for petty crime or police registrations for nuisance, drug consumption, or rough sleeping are not enough, as the Court has decided that expulsion can never automatically follow (several) criminal conviction(s). Instead, the personal conduct of the EU citizens at stake must constitute a genuine, present, and sufficiently serious threat to a fundamental interest of society—e.g., in the case of organized drug trade. A second ground for expulsion is non-compliance with the above-mentioned residency conditions. In other words, if EU citizens do not or no longer have a right of residence as workers, jobseekers, etc., they can be expelled if the measure is proportionate in light of their individual circumstances and complies with fundamental rights standards. As the awkward case of FS shows, however, in a Europe without border controls the fact that EU citizens are always able to return sooner or later does not make expulsion a very attractive option for the authorities.
Explaining systematic exclusion
The most elementary overview of the state of EU law relevant to the treatment of homeless EU citizens reveals how complex that law is. EU rights are not equal for all but rather depend on the personal circumstances of individual citizens and in particular on their socio-economic situation. A considerable number of EU citizens might not be entitled to homelessness services and might even be expelled from host Member States for not complying with the residence conditions. However, it is equally clear that the systematic exclusion of EU citizens from homelessness services is a gross violation of EU law. What might explain this flagrant non-compliance?
The complexity, ambiguity, and relative openness of EU law certainly plays a role. As Dorte Sindbjerg Martinsen and Jessica Thierry Sampson find when researching the role of shelter managers in Denmark, the complexity of EU rules creates a legal limbo that results in fragmented implementation on the ground. When core EU legal concepts such as ”worker,” “unreasonable burden,” etc., are not sufficiently clarified at the EU or national level, their interpretation is decentralized; shelter managers on the frontline are thus left with more discretion than they can or want to manage. As a result, EU law recedes into the background, making way for local interpretations and political agendas that leave homeless EU citizens on the margins of society and “somewhat between the borders.”
However, while complex EU rights certainly get lost in translation, the rhetoric of “non-entitled” EU citizens adopted in the Netherlands and Germany seems to express an altogether different level of exclusion. The presumption of non-entitlement rather signifies a systematic and institutionalized discrimination of persons not despite their EU citizenship but because of it. Such a disconnect between “the law on the books” and the “law in action” seems a clear example of a situation conceptualized as contained compliance by Lisa Conant twenty years ago. While individual EU citizens might occasionally secure their rights before administrations or judges in so-called “single shots,” she argues that discrimination generally persists in the realm of policy and practice because legal principles are generally not translated into broader policy guidelines. This situation can only be altered when Member States are put under adjustment pressures through sustained legal mobilization by (domestic) private actors or the European Commission.
Empirical research in the Netherlands has so far shown that most of the ingredients for a situation of contained compliance are present in homelessness services. For one, homelessness support is characterized by a de facto absence of administrative law. Despite the legal obligation to issue reason-based decisions in written form on behalf of the responsible authority, the large majority of decisions on homelessness services are not made by the responsible authority but by (semi-)public or private organizations and often informally. Clearly frustrating objection and judicial appeal procedures, this practice partly explains the incredibly low level of litigation in this area. Another explanation is the (collective) weakness of homeless EU citizens as litigants before national courts, a situation that can only be altered when civil society, social workers, and specialized lawyers mobilize. Instead, it seems that social workers invest most of their energy in persistently pressuring local gatekeepers to make “an exception” (i.e., to admit an EU citizen to a night shelter), which often requires “escalating” the case to the legal or policy departments of the municipality in question without a formal decision ever being made. In addition, the issue of outsourcing homelessness services to non-governmental organizations (or even profit-making corporations) comes with the problem that these external parties are (largely) dependent on receiving refunds from municipalities or winning the next round of tenders. As Marie-Therese Reichenbach also finds in her research on homeless EU citizens in Berlin, if organizations do something different than financiers prescribe, they can be threatened with losing their funding.
EU citizenship as a marker for exclusion
Homelessness among EU citizens can no longer be seen as an unfortunate coincidence at the margins of a borderless Europe; instead it must be understood as inseparably linked to the social reality of freedom of movement within the European Union. This interconnectedness is the grim result of a political economy of (labor) mobility that reinforces the creation of a European precariat. Member States denying homeless EU citizens equal treatment rights—and EU institutions exhibiting relative tolerance in this area—could also be seen as institutional resistance to economically “unsuccessful” mobility in Europe and to the distressing idea that a life on the streets abroad can be preferred over a return “home.”
The focus of this article is on the law that can protect EU citizens experiencing homelessness abroad (within the Union). In an attempt to decipher some of the complexity and fluidity around these citizens’ rights, the article discusses the range of equal treatment and residence rights that could be mobilized to challenge the bureaucratic, systemic, and institutional barriers that have been put in place to deny EU citizens equal access to local homelessness services. The article also explains the possible legal grounds on which Member States may expel homeless EU citizens who do not or no longer comply with the residence conditions attached to EU citizenship, despite these possibilities being somehow futile in an open border Europe.
The treatment of homeless EU citizens is also a reminder that European rights operate through law and (national) legal systems. The case of the Netherlands shows that even a Member State that prides itself on upholding the European rule of law is capable of systematically excluding EU citizens without much regard for EU law and of ignoring essential principles of (national) administrative law in a context in which collective legal mobilization by or on behalf of homeless EU citizens is lacking. This is not to say that homelessness professionals and organizations ignore the fate of the homeless. On the contrary, professionals work tirelessly to literally save and improve their lives on a daily basis. However, they do so in an adverse context where EU citizenship, rather than engendering a constitutional status presuming a right to equal treatment, increasingly becomes a marker—even a euphemism—for institutionalized discrimination.
Dion Kramer is assistant professor of EU Law at the Vrije Universiteit Amsterdam. He obtained his PhD with a dissertation on EU citizenship, national welfare, and the European Court of Justice. His research now focusses on the law and politics of EU free movement more broadly, including the platform economy, posted workers, and homelessness. In the academic year of 2022/2023, he founded the EU Citizen Rights Corner at the Vrije Universiteit, a legal clinic where master students advise non-governmental organizations about the rights of EU citizens.
 Arrels Fundació, Living on the street in Barcelona: A focus on mobile EU citizens, (Barcelona: Feantsa, 2021): 12, https://www.feantsa.org/public/user/Resources/reports/2022/BCN_report_EN.pdf.
 Of the 225 people living on the streets accompanied by workers of street work association DIOGENES, 49,9% were EU citizens, Feantsa, Mobile EU Citizens Experiencing Homelessness in Brussels: Access To Rights, Employment, And Healthcare, February 2022: 4, https://www.feantsa.org/en/report/2022/03/14/
 Mauro Striano, Intra-EU migrants experiencing homelessness in Brussels: Analysis of field data gathered by DIOGENES street outreach workers, (Brussels: Feantsa, 2020): 6, https://www.feantsa.org/public/user/Resources/reports/BRU_3690_RapportMigrants_EN_1_BD.pdf.
 Home Office, European Economic Area administrative removal, version 3.0, February 2017.
 J. Van de Hulsbeek, J., and S. Ponstein, “Berlijn worstelt met daklozen: ‘We moeten ze ook kunnen uitzetten’,” NOS, October 31, 2017, https://nos.nl/artikel/2200661-berlijn-worstelt-met-daklozen-we-moeten-ze-ook-kunnen-uitzetten.
 Jochem van Staalduyne, “De Gemeente als Uitsmijter,” Groene Amsterdammer, April 20, 2022, https://www.groene.nl/artikel/de-gemeente-als-uitsmijter.
 Or in Dutch: ‘niet-rechthebbende meerjarige overlastgever’, Rijksoverheid, Plan van Aanpak kwetsbare dakloze EU-burgers, September 2022: 9, https://www.rijksoverheid.nl/documenten/rapporten/2022/09/13/plan-van-aanpak-kwetsbare-dakloze-eu-burgers.
 As laid down in article 18 of the Treaty on the Functioning of the European Union (TFEU).
 Dion Kramer, “From worker to self-entrepreneur: The transformation of homo economicus and the freedom of movement in the European Union,” European Law Journal 23, no. 3-4 (2017): 172-188, https://doi.org/10.1111/eulj.12254.
 Preamble 4 of Regulation 492/2011.
 Adrian Favell, Immigration, integration and mobility: new agendas in migration studies (essays 1998-2014), (Colchester: ECPR Press, 2014).
 For a recent account, Vladimir Bogoeski, “Continuities of Exploitation: Seasonal Migrant Workers in German Agriculture during the COVID-19 pandemic,” Journal of Law and Society 49, no. 4: 681-702, https://doi.org/10.1111/jols.12389.
 Aanjaagteam Bescherming Arbeidsmigranten, Geen Tweederangsburgers, (Den Haag: Rijksoverheid, October 2020), https://www.rijksoverheid.nl/documenten/rapporten/2020/10/30/tweede-advies-aanjaagteam-bescherming-arbeidsmigranten.
 Magdalena Mostowska, “Homelessness Abroad: ‘Place Utility’ in the Narratives of the Polish Homeless in Brussels,” International Migration 52, no. 1 (2014): 118-129, https://doi.org/10.1111/j.1468-2435.2012.00782.x.
 Magdalena Mostowska, “Migration and Homelessness: The Social Networks of Homeless Poles in Oslo,” Journal of Ethnic and Migration Studies 39, no. 7 (2013): 1125-1140, https://doi.org/10.1080/1369183X.2013.778037 .
 CJEU, Trojani, C-456/02, ECLI:EU:C:2004:488.
 CJEU, Baumbast, C-413/99, ECLI:EU:C:2002:493, para. 90.
 Feantsa, Mobile EU Citizens, 2022; Maj Kastanje, “Forget about the law: Systematic and multiple exclusion of destitute mobile EU citizens in Denmark,” Homeless in Europe, Winter 2018-2019: 5-6, https://www.feantsa.org/download/2-forget-about-the-law5446828823629584870.pdf.
 As follows from multiple observations in my field research and the EU Citizen Rights Corner. See also, Taeke Damstra, “EU-burgers hebben in beginsel wèl recht op opvang,” Spuit 11, https://www.mdhg.nl/wp-content/uploads/2022/12/SPUIT11winter2022-web.pdf.
 Article 25(1) Directive 2004/38 (‘Citizenship Directive’).
 Article 24 Citizenship Directive, article 45 TFEU. See Hoeckx, C-249/83, ECLI:EU:C:1985:139, paras 20-22.
 For a comprehensive account, see C. O’Brien, E. Spaventa, and J De Corninck, Comparative Report 2015 – The Concept of Worker under Article 45 TFEU and certain non-standard forms of employment, (Brussels: European Commission, 2015).
 Arrels Fundació, Living on the Streets in Barcelona, 2021: 32; Rijksoverheid, Plan van Aanpak, 2022: 10.
 The classic case is CJEU, Levin, C-53/81, ECLI:EU:C:1982:105.
 Article 7(3) Citizenship Directive.
 CJEU, Prefeta, C‑618/16, ECLI:EU:C:2018:719, para. 38.
 Based on a combined reading of articles 14(4)(b) and 24(2) Citizenship Directive.
 CJEU, G.M.A., C‑710/19, ECLI:EU:C:2020:1037, paras 33 and 42.
 For example, Rijksoverheid, Plan van Aanpak, 2022: 10.
 Art. 24 (2) Citizenship Directive.
 Art. 7 (1) (b) Citizenship Directive.
 CJEU, Dano, C‑333/13, ECLI :EU :C :2014 :2358, para. 69.
 CJEU, CG, C-709/20, ECLI :EU:C:2021:602.
 Art. 16(1) in combination with 24(1) Citizenship Directive.
 Article 16(1) and (2) Citizenship Directive.
 Article 17(b) Citizenship Directive.
 Article 27 Citizenship Directive.
 CJEU, Orfanopoulos, Joined Cases C-482/01 and C-493/01, ECLI:EU:C:2004:262; CJEU, Tsakourisidis, Case C-145/09, C‑145/09, EU:C:2010:708. The Court accepted that illicit drug consumption could potentially qualify as a matter of public policy as well, CJEU, Calfa, Case C-348/96, ECLI:EU:C:1999:6, para. 22.
 On the basis of article 15 Citizenship Directive, CJEU, Chenchooliah, C‑94/18, ECLI:EU:C:2019:693 para. 74.
 Chenchooliah, paras 84-86.
 Article 15(3) Citizenship Directive; see Chenchooliah, para. 88 and CJEU, FS, C‑719/19, ECLI:EU:C:2021:506, as discussed in Dion Kramer, “On the Futility of Expelling Poor Union Citizens in an Open Border Europe”, European Papers 6, no. 1: 155-165, https://doi.org/10.15166/2499-8249/459; Fulvia Ristuccia, “‘Cause tramps like us, baby we were born to run’: Untangling the effects of the expulsion of “undesired” Union citizens: FS”, Common Market Law Review 59, no. 3 (2022): 889-914, https://doi.org/10.54648/cola2022056.
 Jessica Sampson Thierry and Dorte Sindbjerg Martinsen, “Lost in translation: how street-level bureaucrats condition Union solidarity,” Journal of European Integration 40, no 6 (2018): 819-834, https://doi.org/10.1080/07036337.2018.1509510.
 Lisa Conant, Justice Contained: Law and Politics in the European Union (Ithaca, NY: Cornell University Press, 2002), 200-207.
 The only published judgment on the issue also arose without a formal decision, District Court Noord Holland, 20 June 2019, ECLI:NL:RBNHO:2019:5631.
 Marie-Therese Reichenbach, “Homelessness of Mobile EU-citizens as One Effect of a National-European Conflict: Insights Into an Ethnography of Participation in Europe Using the Example of Germany,” European Journal of Homelessness 12, no. 1 (2018): 41-60, https://www.feantsaresearch.org/download/12-1_a2_article_reichenbach_v02972066924845204480.pdf.
 Magdalena Mostowska, “Failing to Perform Citizenship: Daily Narratives About Stockholm’s ‘vulnerable EU citizens’,” Sociological Research Online 26, no. 4 (2021): 926–941, https://doi.org/10.1177/1360780421994835.
Image Shutterstock | SCHENGEN, LUXEMBOURG – Monument Schengen Agreement symbolises the free movement of people and goods in 25 European countries.
Published on July 12, 2023.