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Anti-Racism in Europe: An Intersectional Approach to the Discourse on Empowerment through the EU Anti-Racism Action Plan 2020–2025

: Anti-racism in Europe operates in political, policy, and civic spaces, in which organizations try to counter racial discrimination and violence. This paper applies a textual analysis to the European discourse of the transnationally connected anti-racism movement that shaped the European Union (henceforth EU) anti-racism action plan 2020–2025. The plan seeks to address structural racism in the EU through an intersectional lens. Alana Lentin, however, cautions that the structuring principles of anti-racism approaches can obscure “irrefutable reciprocity between racism and the modern nation-state”. Against the backdrop of a critique intersectionality mainstreaming in global anti-racist movements, this paper draws on Kimberly Crenshaw’s concept of intersectionality to critically examine the practices outlined in the EU anti-racism action plan to understand (1) the extent to which the EU anti-racism action addresses the historical baggage of European imperialism, (2) the inﬂuence of transnational anti-racism organizations such as the European Network Against Racism (henceforth ENAR) in reinforcing universalisms about notions of humanity in anti-racism activism through language and (3) the limitations that the EU anti-racism action plan poses for the empowerment of racially marginalized groups of people.


Introduction
The publication of the European Union (henceforth EU) anti-racism action plan 2020-2025 that the European Commission (henceforth the Commission) launched on 18 September 2020 signaled that anti-racism has become "a social priority for the EU" (Pascoët 2020). Prominent anti-racism initiatives, such as the European Network Against Racism (henceforth ENAR) and the International Lesbian, Gay, Bisexual, Trans, and Intersex Association (henceforth ILGA), note that the new action plan is a significant change from earlier attempts to combat discrimination, specifically concerning anti-racism, in Europe. ENAR activist Julie Pascoët, for example, writes that "this plan . . . represents the highest level of institutional recognition of structural racism and its impact on all racialized groups at EU level" (Pascoët 2020). In contrast to earlier steps taken by the EU to address anti-racism, the current plan claims to recognize the structural dimension of racism. The plan proposes an intersectional approach to addressing the specific needs of different groups that experience racism.
According to Anna Carastathis, "intersectionality is a critique of hegemonic politics of representation and how these are reproduced in contestatory discourses such as antiracism and feminism" (Carastathis 2016, p. 163).
The question with which this article is concerned is the extent to which the Commission is able to set political priorities in the fight against structural oppression in a differentiated way, that elevates the experiences of oppression of specific groups of people within minority communities. Does the EU anti-racism action plan 2020-2025 suggest measures that are able to capture the many bases of oppression in the different EU Member states (henceforth EU MSs), or does the EU's approach engender strategies that avert the importance of recognizing that there are different kinds of oppression that members of different minority communities experience?
It is important to note that the most well-known author of intersectionality theory, Kimberlé Crenshaw, argues from the perspective of Black feminist theory. Crenshaw centers that anti-racist agendas have historically neglected the specific contexts in which social problems occur. Using the example of how black women are treated in U.S. court cases on, for example, domestic violence, she demonstrates that if the experiences of oppression that are the basis for anti-racist interventions follow the concept of "racism as experienced by people of color who are of a particular gender-male-" (Crenshaw 1991(Crenshaw , p. 1252, antiracist agendas can erase the experiences of women of color in particular. She explains that if anti-racist efforts articulate racism only along very specific lines, anti-racist efforts employ what Crenshaw terms "strategic silence" (Crenshaw 1991(Crenshaw , p. 1253. "Strategic silence" is the suppression of specific information about intersectional subordination within minority groups, for example, when women of color fall victim to domestic abuse. Crenshaw notes that in such cases "[t]he experience of violence by minority women is ignored, except to the extent it gains white support for domestic violence programs in the white community" (Crenshaw 1991(Crenshaw , p. 1260. Crenshaw warns that anti-racist interventions often reproduce strategic silences. The question that remains in the context of the new action plan against racism in the EU, therefore, is the extent to which the EU anti-racism action plan 2020-2025 falls into the pitfalls of anti-racist legacies. The Commission interestingly seeks to do two things at once with the new action plan. On the one hand, the Commission seeks to expand on previous equality legislation. On the other hand, however, it seeks to disrupt imperialist practices as it takes suggestions from civil society organizations on anti-racist approaches and wants to act intersectional. In practice, that means instating a large number of measures that seek to shape the legal protection of people who experience racism in all areas of life. This includes, for example, incorporating existing equality bodies and implementing a report on the Racial Equality Directive in 2021 with possible legislation suggestions for EU MSs by 2022. Furthermore, the Commission will enforce the framework decision on combating racism and xenophobia, including infringement procedures. The Commission will also publish an Artificial Intelligence (henceforth AI) proposal to address the risk of bias and discrimination of AI systems. Concerning the economy, employment, housing, and healthcare, EU funding will be allocated to these areas to promote diversity and inclusion. The new action plan approaches the area of education by stating that the Commission plans awareness raising seminars on racial and ethnic stereotypes for journalists and civil society. The Commission also wants to introduce mainstreaming inclusion and awareness in education policies as well as mark key commemorative days linked to racism.
Other areas of enforcement include extremism and hate speech, where the Commission wants to identify gaps in tackling violent extremism by 2021, and, in order to do so, work together with IT companies, also with regard to countering hate speech and the promotion of acceptance of diversity online. A key strategy for all of these measures is better data collection for more and better data disaggregated by racial or ethnic origin. Within its own institutions, the Commission will pursue a diversity approach through which the composition of the Commission staff will be critically evaluated, a Diversity and Inclusion Office will be created within the Commission, diversity of Commission staff will be increased to improve representativeness, and a strategy for the Commission's traineeship programs will be developed, alongside the institution of an anti-racism coordinator (European Commission 2020b). Through the combination of multiple equality agendas, the new action plan wants to expand our understanding of what is possible on the EU's equality agenda to imagine a brighter future for all.
Even though, the list of measures appears comprehensive, the new action plan is not free from the legacies of anti-racism mainstreaming. First and foremost, the new action plan does not make explicit how the Commission grounds its understanding of the concept of intersectionality. Carastathis argues that the "deracination of intersectionality from its origins in Black feminist thought" (Carastathis 2016, p. 32) is symptomatic of the way in which anti-racist mainstreaming asks intersectionality to "do conceptual work that seems to invert the very aims of the theorists who inaugurated the concept and of the intellectual and political movements in which it germinated" (Carastathis 2016, p. 86). The negative consequence of anti-racism mainstreaming is that it decontextualizes policy "actions [from] the lived experience of the racialized and promot[es] a universalized vision of equality, and thus the humanity, of non-white, non-Europeans" (Lentin 2004, p. 439). In the pitfalls of anti-racism mainstreaming, how then can the Commission realize its overarching goal of exposing and addressing structural racism in the EU if it does not define what it means by using intersectionality as the chosen revolutionary paradigm?
The Commission pleadges to use the tools of the EU to "build a life free from racism and discrimination for all" (European Commission 2020a, p. 3). Making the argument for anti-racist intervention in this manner suggests that the Commission's plan proposes strategies reminiscent of a practice that Eve Kosofsky Sedgwick termed "reparative reading" (Sedgwick 1997).
Reparative reading seeks to identify spaces of empowerment and innovation, healing and change (Röder 2014). Sedgwick conceptualizes reparative reading as an approach that exposes structures of oppression and looks for pathways for "reparation and indeed hope" (Rao 2020, p. 20). The reparative impulse can be addictive, and burden pathways for reparation, if the exposure of the structures of oppression is the only goal-a practice to which she refers as "hermeneutics of suspicion" (Sedgwick 1997, pp. 4-6). However, Sedgwick also sees a potential for renewal. Katrin Röder convincingly explains that "the act of reparative reading creates novel and subversive nexuses of meaning through connections of formerly separate semantic units as well as novel, provisional, deviant, subversive and alternative self-images" (Röder 2014, p. 61).
If the EU anti-racism action plan 2020-2025, as I argue, pursues a design approach that practices a reparative reframing of anti-racist approaches through what it calls an intersectional lens, we need to understand where it succeeds and where it fails. In the following I analyze (1) the conceptual baggage of anti-racism mainstreaming that informs the extent to which the EU anti-racism action plan 2020-2025 is able to address bases of oppression, (2) the influence of transnational anti-racism organizations such as ENAR in reinforcing universalisms about notions of humanity in anti-racism activism through language, and (3) the limitations that the EU anti-racism action plan 2020-2025 poses for the empowerment of racially marginalized groups of people. Following a brief review of the legacies of anti-racism approaches in the EU that originated from article 13 of the Treaty Establishing the European Community (EC Treaty), I examine the conceptual and practical realms that the EU anti-racism action plan 2020-2025 seeks to employ and provide a critical reading of the axes of power along which they are thought.

The Legacies of Anti-Racism Approaches in the EU
Previously, the EU "characterized [anti-racism] by a long history of declarations of principle in which its character as a transnational norm and definition as a human right" was central (Ruzza 2013, p. 32). However, the new action plan follows a series of policy initiatives that the EU developed to combat discrimination. For example, Articles 2 and 10 of the Treaty on European Union (TEU), articles 19 and 67(3) Treaty on the Functioning of the European Union (TFEU), and articles 20 and 21 of the EU Charter of Fundamental Rights provide the EU legal framework for implementing comprehensive policies on equality and non-discrimination. Most recent examples include the Communication A Union of Equality: Gender Equality Strategy 2020-2025, (COM (2020)152 final), and other targeted approaches to Roma and LGBTQ concerns and disability rights.
The new initiatives build on the EU's foundational declaration against discrimination stated in article 13 in the EC Treaty in 1997. Article 13 explains: Without prejudice to the other provisions of this Treaty and within the limits of the powers conferred by it upon the Community, the Council, acting unanimously on a proposal from the Commission and after consulting the European Parliament, may take appropriate action to combat discrimination based on sex, racial or ethnic origin, religion or belief, disability, age or sexual orientation.
The impetus of article 13 was to promote measures that aid the full integration of people who were previously discriminated against. Instruments developed to combat discrimination at Community level, as Marie Loutridou and Mark Eric Butt importantly explain, can entail binding legal acts in accordance with Article 249 of the EC Treaty (directives, regulations, and decisions), non-binding legal acts (recommendations, opinions, and resolutions), action programs and grants, and mainstreaming approaches (Loutridou and Butt 1999). Article 13 further authorized the Council to take joint action within the limits of the Community, encouraging advocacy coalitions between institutional and non-governmental actors.
Thus, the parameters laid out in article 13 laid the foundation for civil society organizations, such as activist organizations, to become involved with EU institutions. Carlo Ruzza's analysis of civil society's organizations that are involved with EU institutions reveals that in order to take up consultancy in EU institutions, civil society organizations undergo institutionalized accreditation processes and face "the high cost of negotiating an effective presence in Brussels" (Ruzza 2013, pp. 42-43). In 2011, the EU established the "Transparency Register" in which organizations "commit to a Common Code of Conduct and reveal information about their interests, size, goals and finances" to potential collaborators (Ruzza 2013, p. 42). However, only groups who have access to the administrative skills and resources needed to do so can gain access to the European Parliament and decision-making processes. Smaller social movements and community organizations, therefore, often do not benefit from this system. Furthermore, Mark Bell cautions about the autonomy that civil organizations have when they operate in tandem with the EU. Bell proposes that the authorization of civil society organizations by the EU "does not suggest that this is intended to be a specific and autonomous policy competence of the Community[,]" which could be read as an independent source for anti-discrimination law (Bell 1999, p. 10). Besides involving civil society organizations in efforts to stop discrimination, the EU instituted a list of directives about discrimination on the grounds of race and ethnicity (Article 2 of Council Directive 2000/43/EC of 29 June 2000), and on the grounds of age, disability, sexual orientation, and religion (Council Directive 2000/78/EC), which the EU passed in 2000 to extend the previous "gender-only equality policy regime" (Krizsan et al. 2012, p. 2). However, EU directives were not evenly adopted by the EU MSs. Kriszan et al. point out that "[d]iverse legal frameworks, political and discursive structures, and citizenship practices in place [as well as issues of multi-level governance, with many equality institutions operating at regional level] throughout Europe" (Krizsan et al. 2012, p. 5) made a systematic implementation of the EU directives challenging. Another issue with this, as Alana Lentin rightfully notes, was that previous approaches to racism in the EU conceptualized racism in terms of individual and institutional injustices (Lentin 2004).
Putting forth the EU anti-racism action plan 2020-2025, thus, falls in line with a longstanding effort to develop measures that can help facilitate the inclusion of marginalized groups. The goal of the new action plan is, therefore, to use the existing legal instruments and comprehensive EU policy to reinforce specific areas of equality (European Commission 2020a, p. 3) so that the shortcomings of the past can be addressed. The proposed measures stated in the previous section of this manuscript, however, display little critical engagement with structural oppression in the different institutions and processes of the EU. Instead, the Commission seems to insinuate that the central introspective critique has already taken place by stating that at the center of the new action plan is an intersectional approach. Nonetheless, the Commission does not provide a distinct definition of the term "intersectional", which makes it difficult to assess whether the suggested approach can actually help the EU come to terms with the shortcomings of past anti-racism interventions and the EU's historical responsibilities.

The Crux of Language
Given the lack of a clear definition, it is only possible to gauge the Commission's understanding of the term intersectionality from the language it uses to describe how the EU seeks to prevent racism. Using the findings of the Second European Union Minorities and Discrimination Survey by the European Union Agency for Fundamental Rights (European Union Agency for Fundamental Rights 2017) (henceforth FRA), the new action plan has "identified the areas of life where racial discrimination is felt most strongly": work, housing, education, and access to goods and services (European Commission 2020a, p. 4). The four sections of the plan address the conceptual and practical reconsiderations that the Commission is taking to combat these structural dimensions of racism in these areas.
Taking the information of the FRA survey as the basis for designing intervention strategies suggests it is important to be critical of the Commission's claim that it centers the experiences of people who are subject to multiple systems of domination. The Commission's approach to tackling racism lies in that it has still not fully come to terms that its own understanding of how racism is produced by the societies of the EU MSs is incomprehensive and needs radical reevaluation.
The issue of an incomprehensive understanding of racism is visible in the new action plan when the Commission states what kinds of racism the new action plan should tacklein other words, what the Commission identifies as the root of the problem: There are different forms of racism, for example anti-black racism, antigypsyism, antisemitism and anti-Asian racism, that link to religion or belief in cases such [as] anti-Muslim hatred. All share the reality that the value of a person is undermined by stereotypes based on prejudice. In addition to religion or belief, racism can also be combined with discrimination and hatred on other grounds, including gender, sexual orientation, age, and disability or against migrants. (European Commission 2020a, p. 3) This statement reveals that the Commission plans to target the issue of racism in EU societies via addressing "stereotypes based on prejudice" as the primary object of political action. In his analysis of contemporary racism, Étienne Balibar, however, rightfully takes issue with centering "prejudice" in debates about racism. Balibar argues that "prejudice" obscures the structural causes that have shaped "the system of hierarchies and exclusions which, above all, takes the form of racism and sexism" (Balibar and Wallerstein 1991, p. 9). Structural racism means combined modes of oppression that stretch into every aspect of social life in the nation state, for example financial wealth, land rights, health, and education. Racism is, therefore, not a spontaneous phenomenon or merely rooted in attitudes or ignorances. The very issue that racism is rarely "considered to be embedded in the very structures of the nation state" (Lentin 2004, p. 428) has been an ongoing critique of anti-racist approaches.
From the outset of the new action plan, the Commission reproduces the narrative that racism can be discussed outside the bounds of the "historical and contemporary actions of European states themselves" (ibid.). Therefore, the new action plan builds a complex package of measures through which it seeks to tackle individual and structural racism without acknowledging the effects that past and contemporary migration regimes (Lazaridis 2015;Gutiérrez Rodríguez 2018), racial profiling (Goldberg 2002;Law 2014), and complex border strategies (Agier 2011;Yuval-Davis et al. 2019) have had on different minority communities throughout the EU MSs. The Commission is an important actor for anti-racist concerns as it has the highest policy-shaping influence. Therefore, it should be more accurate in the language that it uses to want to bring about change.
Even though the EU anti-racism action plan 2020-2025 states that it recognizes both individual and structural racism, the question remains whether the new action plan's approach can truly be called intersectional. It appears as if the new action plan approaches anti-racism from a point of view that renders the issue of racism marginal, and anti-racism an object of disciplinary intervention. Furthermore, it is unclear whether the EU can achieve the task it set for itself given that anti-discrimination measures have been in place since the 2000 equality directives and yet EU MSs have taken very different approaches to realizing the equality directives.
The EU is limited in the extent of EU interventions in national and regional contexts in the respective EU MSs. However, the Commission's approach to favor strategic litigation as a key national strategy in legislation to bring awareness to infringements on human rights has demonstrated again and again the apolitical nature of EU anti-racist interventions, as Lentin (2004) argues. Anti-racist agendas are often at odds with EU migration policies and approaches to counterterrorism. I follow Lentin in saying that the Commission's apolitical approach, although openly promising to counter both individual and structural racism, is the basis for why racism is able "to persist at the level of the state by releasing it from its historical responsibility" (Lentin 2004, p. 436). This approach allows EU MSs to limit the extent to which the equality directives are recognized, for example through nationalist state and exclusionary migration policies, in order to make sure that the nation state secures its dominant position in the racialized hierarchy that marks the structures of society. Making the case for anti-racist intervention through the Commission is, therefore, at odds with assuring nation states their sovereignty as members of the EU.

Fallacies of Social Inclusion in Anti-Racist Interventions
Furthermore, the language of the EU anti-racism action plan 2020-2025 constructs a narrative that centers the EU's mission for unity as opposed to alleviation of oppression for marginalized people. The notion that social inclusion is a primary concern of the EU is set atop the new action plan via a statement by Commission President Ursula von der Leyen from her speech to the European Parliament on 17 June 2020, which states: We need to talk about racism. And we need to act. It is always possible to change direction if there is a will to do so. I am glad to live in a society that condemns racism. But we should not stop there. The motto of our European Union is: 'United in diversity'. Our task is to live up to these words, and to fulfil their meaning.
Here, von der Leyen enlists all EU institutions, the citizens of the EU in all its Member States, as well as other partners affiliated with the EU through economic, social, and political relations in the mission to realize social inclusion for all.
Von der Leyen's message constructs a reparative narrative that suggests that the Commission's new approach to racism is able to come to terms with previous shortcomings and construct the solidarity needed to heal from the atrocities that racism has brought to all of Europe. Anna Carastathis, however, importantly explains that this is a false universalism that does not get at the core of the issues. She notes that "by reducing intersectionality to an inclusionary politics of diversity rather than to a coalitional politics of antisubordination", an intersectional approach is no more than the mainstreaming of "colorblind" tendencies (Carastathis 2016, p. 112). To understand what Carastathis means by this, we must consider the initial object of critique in Crenshaw's intersectionality theory.
Crenshaw criticizes that anti-racist interventions tend to think "about discrimination which structures politics so that struggles are categorized as singular issues [,thus, importing] a descriptive and normative view of society that reinforces the status quo" (Crenshaw 1989, p. 167). The goal of the intersectional approach, then, is to interrogate "the particular values attached to [the social categories that exist in our world] and the way those values foster and create social hierarchies" (Crenshaw 1991(Crenshaw , p. 1297 in order "to look beneath the prevailing conceptions of discrimination and to challenge the complacency that accompanies belief in the effectiveness of this framework" (Crenshaw 1989, p. 167).
Therefore, it is not enough to embed anti-racist measures in the frameworks of social inclusion. Carlo Ruzza's analysis of the equality directives, for example, already drew attention to the issue when he demonstrated that the legitimacy assigned to new antiracist measures is established only when anti-racism interventions are "connected to the legitimacy of policy focused on social inclusion and anti-discrimination in the public opinion of Member States" (Ruzza 2013, pp. 46-47). If the new action plan is meant to be a reparative tool through which empowerment and healing is possible, the language of the plan must not depoliticize the aim of intersectional approaches. It must challenge the foundational frameworks that (re)create systems of oppression, otherwise, racism is rendered marginal again.
The new action plan's tendencies of leaving old ills uncured is evident in von der Leyen's address. She clearly establishes a connection between the task of combating racism in the EU and the Commission's task of signaling and ensuring the unity of the EU. The all-encompassing statement includes advocacy liaisons that are connected to the EU. As a result of civil society organizations, like ENAR's, close ties to the Commission by way of receiving generous funds for advocacy action and research, civil society organizations are inseparable from the political framework and grammar that the Commission uses to address systemic inequality. This approach situates the project of anti-racism that is laid out in the new action plan within the language of the overall EU integration project.

EU Integration and Anti-Racism Mainstreaming
In order for the EU to be successful as a project, successful anti-racism approaches are necessary. The new action plan states that success of such projects could be measured in lower numbers of reported experiences of discrimination, on the one hand, and higher numbers in diversity within the structures of all EU institutions in all EU Member States, on the other hand. Therefore, an anti-racism approach as laid out in von der Leyen's speech conceptualizes EU integration as an overarching project that is grounded in anti-racism as a fundamental practice. Incorporating concrete measures for anti-racism into the structural apparatuses and action bodies is envisioned to eventually reconfigure the EU in a way that recognizes the needs of the project of the EU as a "union in diversity". The prerequisite for this end would be that all forms of oppression can be eliminated.
Furthermore, there is another dimension to the refiguration process that is embedded in von der Leyen's statement. Articulating the urgency of the needed change from the perspective of a collective "we", von der Leyen implies that if the problem of racism is not solved, the impacts will be felt by all. Section one of the new action plan further elaborates this notion, stating that the Commission aims to "build a life free from racism and discrimination for all" (European Commission 2020a, p. 3). In response to this statement, it may be fair to say that racism affects all areas of economic, social, political, and personal life. However, racism is first and foremost experienced by people who live in a structure within which modes of operation are modes of oppression.
In her analysis of United Nations Educational, Scientific and Cultural Organization (UNESCO) anti-racism mainstreaming, Alana Lentin convincingly argues that it is problematic when anti-racism action "promotes a universalized vision of equality that individualizes humanity without seeing how racism refuses the individuality, and thus the humanity, of non-White, non-Europeans" (Lentin 2004, p. 439). While the new action plan's intersectional approach seeks to ground its actions in the lived experiences of the people who are racialized by way of employing diversity measures and data collection, the new action plan fails to provide a vision toward equality that incorporates reparative steps of reconciliation and reparation that would completely reorganize the policy apparatus to make it possible to think about the prospect of alternative futures, which for Crenshaw is only made possible by involving Black Studies (Crenshaw et al. 2019, p. 48). She argues: If any real efforts are to be made to free Black people of the constraints and conditions that characterize racial subordination, then theories and strategies purporting to reflect the Black community's needs must include an analysis of sexism and patriarchy. Similarly, feminism must include an analysis of race if it hopes to express the aspirations of non-white women. Neither Black liberationist politics nor feminist theory can ignore the intersectional experiences of those whom the movements claim as their respective constituents. In order to include Black women, both movements must distance themselves from earlier approaches in which experiences are relevant only when they are related to certain clearly identifiable causes (for example, the oppression of Blacks is significant when based on race, of women when based on gender). The praxis of both should be centered on the life chances and life situations of people who should be cared about without regard to the source of their difficulties.
From an approach that centers the experiences of racialized people, it can become possible to move beyond making the subjects that policies seek to protect the problem.
Consequently, the EU anti-racism action plan 2020-2025 semantically sets itself up for falling short in providing meaningful supportive state action against racism. The areas of gravest concern in this regard are the Commission's approaches to police violence and diversity measures, which I will address in more detail in the next sections. Much needed reparative practice with regard to the acknowledgement of the violence that European imperialism has caused would need to be reflected in the language chosen to articulate the political framework of the new action plan. Hence, the Commission should seriously reconsider for itself what it means to place the minority communities at the center of its approach. Signpost-acts such as the establishment of a coordinator for anti-racism, which the new action plan proposes in section four, are only short-term solutions. Unless these acts are closely linked with other EU policies, there is no structural change in sight.
At the same time, it is important to acknowledge that there are limits to what the legal frameworks can help achieve. Feminist scholar Wendy Brown cautions that gaining rights alone does not make the system of subordination disappear. Rights only soften the blow. In addition to this, Brown warns that holding on to rights themselves for liberation can increase the likelihood that specified rights can encode further definitions of already oppressed people (Brown 2002, p. 422). In the case of anti-racism interventions, Brown can be read to help understand that the more rights anti-racism seeks to broaden, the more White European society and the EU institutions gain power over the groups that their systems subordinate. The EU anti-racism plan 2020-2025 builds a specific profile of anti-racist work that reproduces specific definitions of the category of race. Unless there is a more careful approach to identifying the specific experiences of oppression that people who live in a context that is governed by multiple different kinds of power, the needs of people will not be at the center.

Legacies of Colorblindness and Chances for Reparative Work
If anti-racist tactics become a matter of justifying race as a determiner of human difference and differences in humanity, anti-racism interventions run the risk of reproducing the colorblind framework that, for example, Alana Lentin convincingly criticizes. With regard to the UNESCO's tradition of treating racism as an individualized problem, she argues that the colorblind approach "circumvent[s] the problem of racism by denying the role played by the state in its origins and perpetuation" (Lentin 2004, p. 439). David Theo Goldberg's comprehensive analysis of racial historicism further illuminates the project of colorblindness as a racial presumption, . . . [that] continues to conjure people of color as a problem in virtue of their being of color, in so far as they are not white. As whiteness studies has so readily and rightly trumpeted as one of its central insights, whiteness remains unquestioned as the arbiter of value, the norm of acceptability, quality, and standard of merit. Color is considered a bruise, a blot on social purity, an unfortunate fact of life to be ignored, seen past yet still seen even if in blurred outline . . . Racially understood, colourblindness is committed to seeing and not seeing all as white, though not all as ever quite, while claiming to see those traditionally conceived as 'of colour' and yet colourless. (Goldberg 2002, p. 223) The logic of colorblindness, as Goldberg argues, is a continuation of the intimate relationship between the history of the modern nation state and its racial definition. He explains that "race is integral to the emergence, development, and transformations (conceptually, philosophically, materially) of the modern nation state" (Goldberg 2002, p. 4). The fallacy of the colorblind framework is that it promises healing at the cost of "making possible the denial of racism as a real experience ensuring the de facto persistence of discrimination against those who in fact cannot be whitened" (Lentin 2004, p. 438, italics in original).
The EU anti-racism action plan 2020-2025 does encourage some reparative practices through which the experiences of racially oppressed people seek to be addressed. Section three of the new action plan presents the Commission's "permanent framework for exchange". Although proposed in an apolitical manner, the establishment of opportunities for regular consultation and dialogue with EU MSs, academia, and civil society via the coordinator for anti-racism can be viewed as an attempt at reparative practice. The Commission seeks "to strengthen policy responses in the field of anti-racism" (European Commission 2020a, p. 24) and, simultaneously, signal that the legislative framework offers space for hope. At the same time, to avert the continuation of racial historicism, such measures of exchange must involve the multiple frameworks of oppression that the EU engages in controlling migration, border policing, and racial profiling.
The current agenda for evaluating racial profiling in EU MSs does not consider practices that happen on the borders between nation states within and on the boundaries of the EU, in externalized refugee camps, or in marginalized migrant communities in EU MSs. If the EU anti-racism plan 2020-2025 does not lead to practices that "historicize the relationship between [states'] evolution into nations, with increasingly imperialist ideals and needs for bio-political power, and the political idea of 'race'" (Lentin 2004, p. 438), promising models for remedial measures will remain mere platitudes.

Civil Society Organizations' Ambiguous Roles
Anti-racist advocacy groups that operate internationally play an important role in the process of making the current anti-racism action plan in the EU. The Citizens, Equality, Rights and Values program and Horizon Europe provide continued funding resources and ENAR is reassured of its position as an important contributor to the implementation of proposed measures. Due to their close engagement with the EU apparatuses, it is necessary to reflect on how groups like ENAR promote meaningful change but can also fall into the trap of using the universalizing promises for achieving social inclusion via an intersectional approach to anti-racist policy opportunistically.
In response to the publication of the EU anti-racism action plan, ENAR and 45 other civil society organizations signed an open letter to the Commission President von der Leyen in which they state that in order to combat structural racism, "[t]here should be a strong focus on ensuring that racialized groups with key expertise from civil society organizations are consulted and engaged in a meaningful and timely manner on the implementation of the plan" (ENAR 2020). ENAR demands that the European Commission applies strong processes that ensure that the new action plan is realized, that targets are clear and measurable, and that progress is monitored. ENAR welcomes that the Commission recognizes the contributions by civil society organizations.
At the same time, ENAR reiterates that the Commission lacks a specific plan that tackles the absence of diversity in the institutions that uphold civil society in Europe. ENAR suggests that the Committee set up "a permanent European Commission advisory committee on anti-racism involving NGOs, Member States and social partners to support the implementation of policies, in particular the framework of National Action Plans against Racism" (ibid.). Furthermore, ENAR underscores the importance that the EU anti-racism coordinator, who the new action plan suggests to instate, "should be appointed based on relevant skills and competences, have strong expertise on anti-racism issues and intersectionality, and be from a racialized group" (ibid.).
The demands that ENAR articulates identify clear weaknesses of the EU anti-racism action plan 2020-2025. It is clear that there will be no sustainable anti-racism legislation from the Commission if the composition of the institutional bodies in Europe does not have representation of marginalized voices as ENAR suggests. At the same time, it is important to remain cautiously optimistic whether ENAR is the entity that can bring about such structural change. Already on 12 June 2020, ENAR, together with ILGA and 150 other civil society actors, published an open letter to the Commission president von der Leyen in which the coalition of civil society organizations demanded that the Commission take immediate steps to address racism. Karen Taylor, chair of ENAR, writes representatively for the coalition that: [f]or decades, ENAR and anti-racist organizations on the ground have been reporting (https://www.enar-eu.org/Shadow-Reports-on-racism-in-Europe-20 3, accessed on: 11 April 2021) what racialized communities experience at the hands of the police across the European Union: discriminatory stop and search, abuse, violence and even death. So far, however, there has been little visibility and no public response . . . The bare minimum that EU leaders should do is acknowledge the existence of and publicly condemn discriminatory and violent police practices, in particular when it results in death. But most European political leaders were not even able to do that. (ILGA and ENAR 2020) Taylor's words resonate with what Carlo Ruzza describes as the limited role that civil society organizations such as ENAR have in the EU (Ruzza 2013). Although, the EU encourages collaboration, being enlisted as a trusted actor by the EU for the purpose of policy dissemination to the public does not mean that civil society organizations are involved in a reciprocal relationship with the EU. While ENAR provides foundational research that the EU can use to conceptually orient its approaches to anti-racism, the EU has in the past not taken full advantage of that work.

The Problems with Superficial Deployment of Intersectional Approaches
Notwithstanding, ENAR itself needs to remain critical of its own language with regard to the suggestions that the organization gives to the EU about the implementation and monitoring of anti-racism policies and other measures. Sirma Bilge uses the term "ornamental intersectionality" to describe the meetings of "neoliberal corporate diversity culture and identity politics" (Bilge 2013, p. 408). Bilge cautions that a "superficial deployment of intersectionality undermines intersectionality's credibility and potentials for addressing interlocking power structures and developing an ethics of non-oppressive coalition-building and claims-making" (ibid.).
At the same time, institutional anti-racist efforts, especially when they receive support from civil society organizations, draw on branding themselves as committed to equality, equity, and diversity. Anti-racism advocacy groups who brand themselves as agents of reparative action construct a marketable expertise in diversity management for themselves. Possessing the image of being able to identify and contribute to the management of diversity can help anti-racism advocacy groups to gain recognition by and access to institutions that possess different kinds of social resources and power. Anti-racist advocacy groups, then, become part of the overall management apparatus for diversity in society, thus, limiting their own abilities to address structural oppression independently.
This critique of advocacy group opportunism is not to say that civil society organizations should not market their expertise to deciding bodies to gain more access to closed off spaces of power. Neither do I seek to downplay the contributions that civil society organizations have made over the years in terms of anti-discrimination legislation using this strategy. However, it is important to note that forming such relationships by way of leveraging action against oppression can be problematic and needs to be addressed. As it was core to the construction of intersectionality theories in discourses by Black feminist scholars to "confron[t] racism within feminism" (Bilge 2013, p. 420), it is important to confront the attempts of cultivating Whiteness-as a reaction to "the perceived threats of growing heterogeneity" (Goldberg 2002, p. 188)-within anti-racist discourse today.
With regard to international queer liberation movements, Rahul Rao notes that liberation movements for marginalized communities are often "haunted by . . . the spectre of abjection" (Rao 2020, p. 25). Drawing on the example of the international queer liberation movement, Rao explains that liberation movements often refigure the marginalized person "as model capitalist subject whose inclusion promises a future of growth and economic dynamism" (ibid.). In the case of anti-racism activism, such pitfalls can be identified when the case for inclusion in society is not made in the language of human rights but as a persuasive move to change the register of inclusion. Rao correctly argues that, in such situations, "the language of the market is deployed to repress an unresolved moral argument about the acceptability or desirability of [the marginalized group] in the nation" (ibid.). The materialist strategy that Rao identifies in regard to global queer liberation movements and their relation to state and market actors is apparent also in anti-racism campaigns.

Limitations of Civil Society Organizations
The close relation between the EU, the economic and political union between nation states, and ENAR, an internationally organized anti-racist advocacy coalition between local and regional actors and organizations across the European nations, speaks to the intricate relationship that evolves when intersectionality is used for gaining power and social resources. Organizations like ENAR, on the one hand, act as activist networks that assist the EU with the dissemination and promotion of anti-racist and other antidiscriminatory policies. ENAR groups also lend their perspective on inclusion of ethnic minorities. In addition to this, ENAR groups publish scientific analysis of social issues related to racism that inform new policies and make links between migration and antidiscrimination known. On the other hand, ENAR financially benefits from its enlistment in EU initiatives as it receives around 90 percent through EU contributions (Ruzza 2013, p. 44). While the EU heavily relies on input by civil society organizations such as ENAR, the financial dependency that is created between the two begs the question whether civil society organizations can maintain their independence from EU agendas to provide reflection and point out voids.
Carlo Ruzza (2013) convincingly notes that the implementation of anti-discrimination policies, in particular with regard to anti-racism, serves the Commission as a tool to disseminate a particular narrative about the EU. The aim is to portray the identity of the union as one that is united in diversity. In order to realize this goal, the Commission enlists the assistance of anti-racism organizations "as a channel to reach local communities through a top-down process and use these contacts to disseminate EU policies which have lifestyle implications, such as the promotion of anti-discriminatory behaviour" (Ruzza 2013, p. 42, ctd. in Ruzza 2006. The Commission uses its liaisons with civil society associations like ENAR to legitimize "EU anti-racist efforts . . . [and] the policy focused on social inclusion and antidiscrimination in the public opinion of Member States" (Ruzza 2013, p. 47). Due to the fact that EU-level organizations such as ENAR take an important mediating position between different interest groups, the paradigmatic use of intersectionality as a tool for establishing and maintaining the relationship between ENAR and the EU comes at a cost to the communities that anti-racism seeks to serve.
For example, ENAR's report on intersectionality problematizes the mainstream understanding of individual racism "as an intentional act perpetrated by one prejudiced individual against another person or group of people based on race, skin colour, gender or any other axis of discrimination" (European Network against Racism and Center for Intersectional Justice 2019, p. 14). ENAR's report was published ahead of the composition and publication of the EU anti-racism action plan 2020-2025. Regardless, the Commission did not take full advantage of ENAR's findings. Instead, as previous examples have outlined, the new action plan falls short to acknowledge the relationship between universalism and racism inherent in the Commission's understanding of racism in the EU.

Universalisms and Racism
Étienne Balibar's examination of the structural causes of racism is helpful to understand the relationship between racism and nation states and the practices of universalism in policy. He explains that contemporary forms of racism affect all aspects of life, including the social, economic, and political engagements of people, and the historical imaginaries they form therein. Therefore, it does not suffice to understand racism as a singular development that "revitalizes typologies and reworks accumulated experiences" to reveal to the world that the way in which we believe humanity came into being is not correct (Balibar 1991, p. 44). He goes on to explain further that traces of certain forms of racism function as screens for others, while simultaneously representing the "unsaid" of those other traces. Showcasing that different forms of racism can be a register for many more forms of oppression, Balibar explains that compounding multiple expressions of oppression work toward denying a specific group the right to freedom and humanity (Balibar 1991, p. 45). He gives the example of xenophobia to demonstrate that the way in which classifying criteria by which the humanity of a person is assessed presupposes a hierarchical form of ranking. Even when other signifiers such as "culture" are substituted for that of race, markers such as "heritage" and "ancestry" are attached to elaborate the relation of a person with their origin (Balibar 1991, p. 57). Doing so creates idealized descriptions of the human ideal, and with that, idealizations of "the perfect type of humanity" (Balibar 1991, p. 58) and, simultaneously, insinuates its opposite.

United in Diversity
In relation to Balibar's critical reflection on universalism and racism, there is something to be said about how the construction of modes of racial oppression is imbued in the idealized projection of EU identity as "unity in diversity". Multiple actors, including international anti-racism advocacy groups, EU institutions, EU MSs, and (White) EU citizens contribute to the production of anti-racist practices as an approach that offers (White) EU citizens the possibility of freeing themselves from the accusation of racism. The promotion of anti-racism through a series of actions that change the supra-nationalist structures of the EU, therefore, can also serve the construction of an idealized pathway through which the EU, as a holder of power, hopes to free itself from racism. Although this approach may not be the intent of the EU anti-racism action plan 2020-2025, the new action plan's mission cannot be viewed independent from the underlying project of European imperialism because the Commission is embedded in, and operates from, the structures that uphold the principles and goals of nations (Lentin 2004, p. 430).
The issue is that institutions that anti-racist interventions seek to target tend to deracinate themselves to occlude their complicity. Therefore, in order to be effective, the EU anti-racism action plan 2020-2025 needs to be more critical of previous legislation and its application of intersectionality as a conceptual framework. The Commission should interrogate the ways in which the universalism that the new action plan propagates are constructed without referencing how the historical practice of racism was institutionalized. I follow Lentin in stating that a failure to recognize the historical contingencies that assert dominance will result in future policies that will only participate "in compounding the logic of racial historicism" (Lentin 2004, p. 440).
Alana Lentin draws on Balibar to note that contemporary forms of racism "cannot be fully understood without a concomitant engagement with the history of the development of the notion of universalism and the project of conceiving a general 'idea of man'" (Lentin 2004, p. 429). Thus, racism is not a matter of individual prejudice, as noted in the EU anti-racism action plan 2020-2025. Instead, "race" is a political idea, Lentin writes, that relies on the ideological and methodological framework that the Enlightenment created to uphold the principles and goals of the nation (Lentin 2004, p. 430).
The conceptual framework of the EU anti-racism action plan 2020-2025 should, therefore, reflect mainstream strands of anti-racist understanding, as Lentin calls it. By that, she means the common, but often false understanding of racism that was largely promoted by institutions such as UNESCO. Drawing on Lentin, I argue that the new action plan needs to seriously acknowledge this gap and revert from the individualization of racism as a problem of pseudo-science. Furthermore, the new action plan should regress from proposing alternative definitions of difference such as culture and ethnicity (Lentin 2004, p. 439). As long as the Commission does not acknowledge that there will remain, as Lentin describes: the impossibility of equality as premised on the assumption that each and every individual has the opportunity to attain the humanity encapsulated by the universalist vision . . . if the universalistic ideal of humanity is founded upon the European, white model, it will simply not be possible for the Others that human rights seek to protect to gain entrance to that community of individuals. (Lentin 2004, p. 440) contemporary anti-racism initiatives will continue to jump into the "specter of abjection" ( Rao 2020) and not be able to achieve the necessary reparative work that it needs to come to terms with the ways in which contemporary problems are entangled with the racial and colonial histories of the European nations.

Risks and Chances of Intersectionality in Policy
Even though the reparative approach to racism that the EU anti-racism action plan 2020-2025 suggests considers structural locations and power differentials, the paradigmatic use of intersectionality that the new action plan presents may risk intersectionality becoming "a universal device to be applied as an invariant rule" (Bilge 2013, p. 420). Bilge notes that intersectionality is no objective analytical tool, thus, it does not suffice to acknowledge that there are different experiences of racism without acknowledging that there are different bases of oppression that cannot be added up like a "shopping list" (Bilge 2013, p. 420) to make arguments for liberation. Instead, it is just as necessary to recognize the different conditions that have created the bases for structural oppression, as it is important to recognize the different kinds of knowledges and resistance that have developed as a result (Bilge 2013, p. 419).
Therefore, the Commission tries to avoid thinking of different categories of discrimination as separate from each other. In order to provide a reparative practice, the action plan provides opportunities to acknowledge the different ways in which experiences of oppression may be marked. For example, the Commission identified that the specific function of hatred is to sustain the subordination of historically subordinated peoples (Brown 2002, p. 424). The new action plan, thus, places great care on identifying different spaces in which hate is expressed, especially online. In Section 2.1, the plan states that the Commission is expanding "effective, proportionate and dissuasive criminal penalties throughout the EU" that the framework decision on combating racism and xenophobia by means of criminal law (2008/913/JHA of 28 November 2008) laid out via "a full and correct transposition and implementation" of the Victims' Rights Directive (2012/29/EU), which "requires Member States to ensure a fair and non-discriminatory treatment of victims of crime, with particular attention to victims of crime committed with a bias or discriminatory motive" (European Commission 2020a, p. 6). Specifically, the new action plan details a planned digital services act that among other concerns of cyber security will include a reporting system for experiences of hate speech. The new action plan hopes to contribute to the safeguarding of freedom of expression online but also be a basis that can "[help] civil society and policymakers . . . formulate policies that effectively target racism" (European Commission 2020a, p. 7).
To understand the opportunities and limitations of the new action plan's approach to the issue of hatred, it is useful to return to Crenshaw's concept. Kimberlé Crenshaw first coined the notion of intersectionality in her 1989 article in which she analyzed the manner in which the needs of Black women were insufficiently addressed through the mainstreaming of anti-discrimination doctrine in the United States (Crenshaw 1989). Crenshaw surveyed a series of court cases in which courts were not willing to allow the claims by Black women plaintiffs. Rulings on sex discrimination cases were articulated with regard to race-and class-privileged White women and rulings on race discrimination were considered from the experiences of sex-and class-privileged Black men. There was a lack of clarity that people may experience discrimination by way of multiple categories of discrimination. Furthermore, the categories of discrimination that were identified were defined through the experiences of middle-class White women and Black men. Thus, Black women could not be represented by some combination of any of these categories as these categories do not speak to the experiences of Black women. Crenshaw importantly pointed out that in the place of (impossible) intersection, to borrow Rahul Rao's phrasing (Rao 2020, p. 14), the experience of Black women is erased.
While multiple forms of discrimination may intersect, they are not separate layers or separate axes at a crossroads. Contrary to critiques of intersectionality through the "infinite regress objection", which "assumes the stability and explanatory power of monistic categories even as it explores their permutations and combinations" (Carastathis 2016, pp. 148-49), Carastathis argues, intersectionality is aware of the thorny issue that depending on the social context, social experiences of multiple oppression may be flattened or fragmented. By that, Carastathis means that intersectionality leaves the option to opt for single-issue approaches if the issue at hand had to be prioritized. However, Sirma Bilge importantly notes that such prioritization was always temporary and strategically done (Bilge 2013, p. 419).
What does the conceptual work mean for the implementation of measures against hatred in the EU? The new action plan's approach to stopping online hatred as an anti-racist strategy reveals that countering racism as a form of hatred can be useful to approach as a single issue. The space of the internet is so vast that national and supranational entities like the EU and its MSs have limited resources to identify social experiences of racism online. Furthermore, the internet is a relatively new space of governance in which nation states and supra-national entities such as the EU have only governed for about twenty years. The 2014 Communication, for example, called for "establishing a coherent set of global Internet governance principles that are consistent with fundamental rights and democratic values, with all stakeholders" through cooperative governance frameworks with shared rights and responsibilities among the EU MSs (European Commission 2014, p. 4). Already, the 2014 Communication opted for a multistakeholder approach to internet governance because of issues of unequal access to resources for certain EU MSs, a lack of trust in the structures of the internet, and a lack of resources to address the multiple concerns that have arisen over the past twenty years, with the expansion of broadband connection and technology developments.
Considering the multilevel obstacles with which the EU is faced in governing online spaces, pursuing a single-issue approach when addressing hatred online is understandable. While a more nuanced approach to illegal practices of racial discrimination online would be welcomed, the Commission has found an interesting approach that allows for placing the issue of hatred online into the focus of internet governance to argue for protection of the social experiences of racism that people make online.
However, there is also criticism about the EU's attempt to interfere in the policing of hate speech online. Maryant Fernandez Perez from EDRi, for example, argues: The illegality of the content is assessed in relation to companies' Terms of Service and 'where necessary' vis-à-vis national laws. In practice, this means that content will always be deleted on the basis of Terms of Service, so there's never a need to check the content against national laws on hate speech. (Dachwitz 2016) Regardless, the integration of racism as an issue in online hate speech through single-issue political movements such as the EU anti-racism action plan 2020-2025, using the words of Carastathis, can be viewed as a "strateg[y] of survival for those who are regarded by their "natural" communities as outsiders, traitors, and fakers" (Carastathis 2016, p. 196). Such microscale versions of political coalition to which Carastathis refers emerge out of necessity for coalition. In this regard, the new action plan offers hope, but hope only if long-term strategies will be developed that prevent the policing of hate speech online becoming part of the cultivation of Whiteness in language online.

Reparative Action and Empowerment-A Possibility?
The failure to address the historical contingency of racism in the EU's language to anti-racism approaches is problematic. The question, thus, remains, under what conditions can empowerment be possible? This paradox is particularly visible in the new action plan's approach to countering discrimination by law enforcement authorities. In order to prevent the continuation of different forms of racial discrimination, the Commission suggests to address the issues of discriminatory attitudes within law enforcement, specifically profiling. The new action plan acknowledges that there is a need for structural changes to tackle the lack of "trust in authorities" because many crimes and resistance to public authority are underreported (European Commission 2020a, p. 7). The Commission proposes a multilevel approach that involves "mapping the gaps and needs in EU Member States, and training action to detect and prosecute hate crime" as well as building training manuals and training packages to "sharpen awareness of fair and inclusive policing" (ibid.). The Commission hopes that implementing these measures will help develop key guiding principles to increase the currently low reporting of hate crimes.
Even though the Commission's new approach to policing and addressing internal structures of discrimination in the police force is a helpful step toward justice for marginalized groups, it is no strategy of empowerment. Çagrı Kahveci's analysis of empowerment in social movements reveals that empowerment can only be achieved through a form of politics (Ranciére et al. 2001) that disturbs the existing organizational order of a structure and its police. Drawing on Jacques Ranciére's concept of politics as a disruptive power (Rancière 1999) to evoke social change, Kahveci argues that people can achieve a space for themselves in which they create possibilities for themselves and make room for the oppressed voices of the subaltern to state their ideas and interests (Kahveci 2017, p. 37). Therefore, empowerment involves the authorization of marginalized groups through disruptive politics, so that they can demand their rights, gain access to public resources, and become involved in decision-making processes that promote the development of society as a whole (Kahveci 2017, p. 36).
A close look at the new action plan's proposal for disruptive change in policing, however, reveals that the Commission does not seek to realize effective and sustainable structural changes in law enforcement. Instead, the plan follows an integrationist approach that views the concerns of people who are particularly vulnerable to policing and police brutality as a marginal concern in the overall foundational framework of law enforcement. Furthermore, the new action plan misses the opportunity to implement the strategy of community policing, which the FRA identified as a useful strategy to reduce crime and fear of crime in its 2018 report on the experiences of discriminations that Black people make in Europe (European Union Agency for Fundamental Rights 2018). The measure of the EU anti-racism action plan on policing would benefit from exploring such forms of community policing that redistribute responsibilities to the members of marginalized communities.
Further lack of measures that strive toward the reorganization of different areas of life reverberates the exclusionary strategies typical of the European migration regime and its violent practices in outsourced border control points and refugee camps. The anti-racist interventions proposed to law enforcement agencies via the new action plan can, therefore, only be understood as a strategy to ensure temporary survival. Audré Lorde famously reflects on her experience as a Black lesbian woman with regard to the notion of survival in the American university context. She writes: It [survival] is learning how to stand alone, unpopular and sometimes reviled, and how to make common cause with those others identified as outside the structures in order to define and seek a world in which we can all flourish. It is learning how to take our differences and make them strengths. (Lorde andClarke [1984] 2007, p. 107) While, on the one hand, increased security and protection for people who experience racism may secure their survival, it is not a strategy that would enable them to be recognized as equal members in society. Alana Lentin explains that "if the universalistic ideal of humanity is founded upon the European, white model, it will simply not be possible for the Others that human rights seek to protect to gain entrance to that community of individuals" (Lentin 2004, p. 440). Therefore, arguing for the rights of people who are racialized by way of human rights and protection measures resonates with Lorde's warning that "the master's tools will never dismantle the master's house" (Lorde andClarke [1984] 2007, p. 107). In "Manifesto for Survival", Sadiah Qureshi elaborates the dimension of survival in that the next needed step would have to be "changing the balance of power" (Qureshi 2019, p. 213) so that marginalized people are included. Policies for meaningful change can be proxies for a transversal reconstitution of power.

Conclusions
Overall, the current EU initiative on anti-racism is embedded in a series of concrete steps that the union is taking to ensure that the EU Charter of Fundamental Rights is realized in all its member states (European Commission 2020a, p. 4). This article has laid out a critical examination of the conceptual and practical suggestions made by the Commission to combat racism and foster empowerment, with particular attention to the language that the new action plan uses. While the Commission aims for a reparative approach through which structural changes for the benefit of racially marginalized people in Europe is to be achieved, the EU anti-racism action plan 2020-2025 has its limitations that are grounded in the historical and temporal context in which the plan has been articulated.
There are deep issues with such a universalizing approach to anti-racism. When the specific historical and temporal contexts in which the power dichotomy is articulated are removed or artificially shifted, the historical contingency and the political history are obscured. The Commission seeks to avoid such violent acts, however, simultaneously employs marginalized people as informants for implicit bias trainings and diversity hires.
I have argued that the crux of the EU anti-racism action plan 2020-2025 lies in its language. The new action plan is part of the EU integration framework whose political grammar enlists the anti-racism initiative in a range of other issues. On the one hand, anti-racism is conceptually articulated as an integral part of the unity of the EU. On the other hand, engaging in anti-racist practices via the EU institutions, but also in everyday life, contributes to the practice of life as a (White) European.
Enlisting anti-racism as a project within the larger dimension of EU integration reproduces the structures of European imperialism. The new action plan proposes an intersectional approach, but never fully defines what it means by that or how it plans to employ this approach. Consequently, we learn about the voids of both policy measures and the voids made visible by the compounding of different areas of life affected by racialized oppression. However, the plan does take important steps to address these voids. Throughout the future development of anti-racism initiatives, it continues to be of utmost importance that any anti-racism approach addresses the reciprocal connection between universalism and racism, in order to avoid anti-racist initiatives becoming enlisted in idealized pathways to (White) Europeanness.
Furthermore, I have considered the role of the transnationally connected civil society organization ENAR that has long been deeply connected to the EU and its mission to combat different forms of discrimination. While ENAR provides the EU with extensive research and resources, from which the Commission can draw to articulate its policies, there is no reciprocal exchange or agreement that ENAR's findings will be implemented. The limited opportunities that ENAR has at its disposal for interventions raise pertinent questions about the independence of civil society organizations and the limitations of their work. However, ENAR's international network of partner organizations, such as ILGA, provides an important tool in exerting political pressure on the EU to act on behalf of ENAR's concerns. ENAR is fully aware of its role to the Commission and uses its position as an important entity for policy dissemination to the public as leverage to mobilize internationally. The importance of different forms of civil society mobilization increases and the availability of EU resources for anti-racism initiatives in Europe is guaranteed for the duration of the EU anti-racism action plan 2020-2025. Thus, the shifts in current EU legislation, although they have limitations, warrant a certain degree of hope that there will be space for reparative practices to develop in the future.
Funding: This research received no external funding. The content of this publication represents the views of the authors only and is their sole responsibility. The European Commission does not accept any responsibility for use that may be made of the information it contains.

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Data Availability Statement:
No new data were created or analyzed in this study. Data sharing is not applicable to this article.