It’s been several months now since President Donald Trump announced his intention to reform the U.S. immigration system. In a speech addressed to Congress on Feb. 28, he reiterated his desire to draw inspiration from Canada, which is more selective in its choice of immigrants. In the U.S., about two-thirds of permanent residents are admitted to reunite with family members. Less than 20 percent are admitted because of their professional skills. In Canada, by contrast, it’s almost the opposite: more than 60 percent of permanent residents are admitted via the economy class, and only a quarter are admitted because of family reunification.
Famously, the Canadian immigration system is based on a point system: applicants for immigration are assessed on the basis of a number of factors, including level of education, language proficiency, age and professional expertise. The introduction of the Express Entry system in 2015 reinforced the selective nature of the process: potential immigrants who obtain the most points in the tests (and who are therefore expected to better integrate into the labor market) have accelerated access to permanent residence — often in less than six months.
It is difficult to know exactly what will constitute Trump’s merit-based system. In any case, there are many reasons why the Canadian system is difficult to transfer to the U.S.
1. Undocumented migrants are a particularly American dilemma
For geographical reasons, Canada, which does not have a border with Mexico, is not confronted with the same scale of undocumented workers. The number of undocumented migrants in the U.S. is estimated at more than 11 million. The figure is between 20,000 and 200,000 for Canada.
Trump has promised to deport undocumented immigrants, whom he accuses of pulling down wages for American workers. However, many of these immigrants work in low-skilled jobs — in the manufacturing sector, in construction or in agriculture. The latter industry, for example, relies heavily on these undocumented immigrants: according to the American Farm Bureau Federation, they represent between 50 percent and 70 percent of the labor force in agriculture.
Beyond logistical and cost problems, massive deportation would create a labor shortage in key sectors, resulting in serious economic consequences. States like California or Texas, which employ a high number of undocumented workers, would be particularly affected by massive deportation. Even if, for the sake of argument, one supposes that deporting undocumented immigrants would increase wages for low-skilled employees, it’s dubious that it would be beneficial to the U.S. economy as a whole.
2. Why unskilled workers are necessary
More generally, the idea that the U.S. has to switch to a Canadian-style selective immigration policy is also misleading because it does not take into account the economic structure of the large American labor market. Insisting on the need for high-skilled workers — Indian engineers in Silicon Valley, for example — avoids the fact that the economy has a structural need for low-skilled labor. Hotels, food service, cleaning, elder-care, wholesale and hospitality employ a high number of unskilled foreign workers. Even in a high-skilled knowledge economy, workers are needed for food preparation, construction, children and elder-care.
If measures to limit low-skilled immigration were introduced, even if it had a positive impact on the wages of native workers as the Trump administration hopes, they could lead to a shortage of labor in several key sectors that deliver daily services to the Americans. The native population is unable to meet the demand. California field laborer wages have reportedly risen by nearly 50 percent from 1996 to 2015. However, this raise has not attracted more native-born American workers. Farmer employers argue that this is due to the harsh working conditions of agricultural jobs.
Another explanation could lie in what British classical economist David Ricardo called “comparative advantage”: the low-skilled native population tend to focus on jobs that require the ability to speak English, whereas immigrants concentrate in manual jobs that do not need English proficiency but that generally imply a more precarious working environment. The economic structure of the post-Fordist job market is stratified according to countries of origin and immigrant status in the U.S.
3. Why it’s so difficult to implement immigration reform in the U.S.
In order to develop a sustainable immigration system along the lines of Canada’s, the U.S. would have to undertake comprehensive reforms that overhaul the different components of immigration law: low-skilled labor, high-skilled labor, border security, undocumented immigrants and the enforcement of domestic laws. These different elements are related and must be considered at the same time. But, for institutional reasons, it is difficult to implement such a reform.
In the U.S., immigration is a highly divisive topic; it is very easy to block immigration reforms — even minor ones. Even a small modification, such as increasing the quota of the H1B visas that are often issued to skilled workers, must be validated by Congress. Thus, any reform project tends to be dragged into political maneuvering and ideological rivalries in Washington.
In the recent past, former Presidents George W. Bush and Barack Obama both tried and failed to institute a comprehensive immigration reform. The most recent example is Bill 744, introduced in the Senate in 2013, which sought to modernize the U.S. immigration system in several respects, including border control and access to citizenship. This bill was passed by the Senate by a large majority (68 to 32). But the House of Representatives refused to consider it, so most of the proposals were never put in place.
Any substantial reform is likely to end with a legislative stalemate. U.S. presidents can still issue executive orders, but the effect of these is, by definition, more temporary and does not involve rethinking the architecture of immigration policies.
Insisting on the need for high-skilled workers avoids the fact that the economy has a structural need for low-skilled labor.
Conversely, Canada’s immigration system has undergone several changes over the last two decades, notably in order to match immigration with the changing economic needs of the country. The minister of immigration has substantial room to maneuver and powerful legal tools to support changes. If adjustments have to be made in immigration policy (e.g., modifying the weight of certain factors in the point system), this can be done through the minister of immigration and does not need parliamentary approval. Overhauling the U.S. immigration system in order to make it more like the Canadian model would therefore be a near-impossible task because of the different legislative architectures of both countries and because the issue of immigration is much more divisive in the U.S.
Trump is not the only one inspired by the Canadian immigration model. Several European governments have also looked at Canada in order to better compete in the global race for talented immigrants. Canada is known as a tolerant society, based on its reception of large numbers of immigrants while being selective and keeping strict control of those entering its territory. Of course, it is politically profitable to claim to want to be inspired by a country with a good reputation. Beyond political slogans, however, it should be recognized that the Canadian model is not readily transferable for economic, geopolitical and institutional reasons.