Racism toward the Roma through the affordances of Facebook: bonding,laughter and spite

Introduction

It has been well documented that the Roma have experienced centuries of discrimination and social exclusion, which continues today (Achim, 2004; Korando, 2012). Scholars have drawn attention to a number of well-established discourses which naturalize, legitimize and perpetuate this situation: these discourses allude to Roma criminality, illiteracy, immorality, promiscuity, laziness and resistance to integration into mainstream society (Catalano, 2018; Creţu, 2014; Hancock, 2008, 2010). Media researchers have also found that news outlets across Europe have represented the Roma in terms of these same discourses (Catalano, 2012; Cheshmedzhieva, 2009; Erjavec, 2001; Tremlett et al., 2017) but, in addition they also blamed the Roma for their own vulnerable position in society (Tileaga, 2005). In this article we carry out a multimodal critical discourse analysis (MCDA) of 1500 comments posted in response to a news-clip about a Roma wedding, that was shared by Rasul (The Laughter), a Romanian media-based Facebook company, which brings together material presented as funny, from across the Internet. The news-clip had originally been broadcast by Romanian Antena1 News and followed the style of the ‘documentary series’, Big Fat Gypsy Weddings, aired by the British Channel 4.

These documentaries claim to give insights into the lives of the Roma. Yet they have been criticized for perpetuating existing stereotypes as they portray a community which is either spectacular, extraordinary and above all, negatively different (Tremlett, 2014: 316), or one that is primitive, ruled by oppressive traditions and cultural practices, including excessive consumption patterns (Jensen and Ringrose, 2014). More importantly, apart from inciting moral outrage, such TV shows ascribe the discrimination experienced by the Roma communities to their culture rather than to social injustice (Jensen and Ringrose, 2014). More broadly, this kind of reality programming has been challenged for inviting viewers to take a superior moral position and to mock and ridicule the participants (Eriksson, 2015) through what Billig (2005) might call a highly aggressive disciplinary humor.

In this article, the analysis of these Facebook posts which respond to the news-clip, is highly valuable since in critical discourse studies (CDS) it has been argued that social media can provide an important source of data to reveal how the wider population takes up, engages with, and challenges dominant discourses and ideologies in society (KhosraviNik, 2017). These Facebook comments are one such instance where we can investigate what discourses are used by posters to comment on the film and its Roma protagonists.

Our analysis reveals that those who post on this Facebook page do take up Rasul’s invitation to laugh at the Roma while presenting themselves as superior. The discourses they use align closely with the negative representations already documented by scholars. But we show that the affordances of Facebook open-up the possibility of mixing of humor, venting of frustration, extreme racism, and sexual violence as those postings entertain each other, create bonds, and overtly call out the Roma and others who are believed to be part of a conspiracy against ordinary Romanians. We argue that this conspiratorial aspect and how it links to the more long-standing discourses is part of what scholars have described as a rising extreme right-wing ideology throughout Europe and in the United States, which have led the political success of many right-wing politicians such as Trump in the United States, Orbán in Hungary and the phenomena of Brexit in the United Kingdom (Wodak and Krzyżanowski, 2017).

We begin the article by providing contextual details relating to the Roma in Romania, particularly the period following the collapse of communism in 1989 to the present-day mobility of both Roma and Romanians throughout the EU. This is relevant for understanding some of the points of reference made by the postings on this Facebook page.

The Romanian Roma

In all, 2.5 million of Europe’s 12 million Roma live in Romania, a country of 19 million inhabitants. Scholars have documented how the Roma, at present and over many centuries, have experienced racism, marginalization, extreme poverty and violence, including their victimization during the Holocaust, and have always been viewed as a ‘social problem’ that needs a solution (Achim, 2004; Bunescu, 2014; Korando, 2012).

After the collapse of the communist system in Romania, there was a period of social and economic upheaval, inflation and recession, where older economic formations and relationships broke down (Ladányi and Szelényi, 2001). These changes greatly worsened the situation of the already highly vulnerable Roma who were most affected by the economic transition (Ladányi and Szelényi, 2006). Poverty levels of the Romanian Roma (68.8%) soared compared with the rest of the population (29.5%) (Ringold et al., 2005). The position of the Roma gradually deteriorated as the period was characterized by a rise of ideological nationalist discourses fostering intolerance for ethnic minorities (Themelis, 2016); this is also the time when right-wing populism started to take shape in the former communist countries, including Romania (Wodak, 2015).

Romania’s accession to the EU in 2007, corresponding with economic crisis throughout Europe, was an opportunity for large numbers of people from Romania, including the Roma, to migrate to Central and Western Europe in search of jobs and opportunities. Yet, such migrants were by no means necessarily welcome (Catalano and Fielder, 2018; Fox et al., 2012), as they were often perceived as a threat to the material and economic resources of the countries to which they migrated (McMahon, 2015; Uccellini, 2010). In the context of the economic crisis and austerity measures being implemented across the EU, the Roma became easy targets for politicians who sought to consolidate their own positions or distract the public’s attention from actual problems, such as financial cutbacks, lack of jobs or declining access to social welfare (Fekete, 2014; Nacu, 2012; Themelis, 2016). The Roma became victims of the highly controversial actions undertaken by a number of governments, being repatriated from Germany, Belgium, France and Italy and experiencing visa entry restrictions in Finland, Norway and Denmark, practices which all directly contravened EU protocols ¹ in reference to the treatment of minorities (Breazu and Machin, 2018; Korando, 2012; Richardson and O’Neill, 2012) and which were highly criticized by human rights organizations (Amnesty, 2012a, 2012b; ERRC, 2016). It was observed that such repatriations were part of a systematic scapegoating by conservative governments concerned with consolidating their own positions (Kirchgaessner, 2018; McGarry and Drake, 2013; Nacu, 2012).

After Romania became part of the EU in 2007, the country repeatedly sought but failed to gain full access to the Schengen zone. The rejection was based on the lack of progress on internal judicial reform (especially in the fight against corruption) and slow progress on border security (Economist, 2013). However, the Romanian government publicly explained the Schengen failure as being down to fears of wide-scale Roma migration across the EU (Găină, 2013). Later the controversial actions of EU governments aggressively repatriating the Roma were used as evidence, not for growing intolerance of migration in the EU, but for the so-called problematic nature of the Roma and the burden that they create for Romania and for the Romanian people (Breazu and Machin, 2018).

Social media and social and political debate

It has also been suggested that social media have created huge shifts in how we debate social and political matters in society. It has meant that the expression of views on social and political matters has become a ‘mass phenomenon’ but also that it has led to huge polarizations of viewpoints (Krzyżanowski and Tucker, 2018: 143). Social media forums, far from fostering wider civic engagement and democratic participation, can rather lead to a retreat into opinion where people interact within ‘nodes’ where views tend to become more entrenched (KhosraviNik and Unger, 2015).

Discussions of social and political issues on social media have also been observed to be characterized by a shift away from debate using more developed and clearly articulated ideas to those which reply on simple polarized narratives (Papacharissi, 2015). Papacharissi (2005) looked at examples of where social and political movements on social media platforms lacked coherence and clarity in terms of the identified problems and the solutions which are being sought. What bound such movements together is the flows of affect communicated largely symbolically and through simple and polarized narratives, as people claim solidarity with the ‘movement’, post love-hearts, symbolic images, emojis, and express moral alignment. This drove a powerful sense of what she calls ‘affective connectivity’, where, of course, it may be difficult to post comments which counter the flow of this affect. It is this level of affect which in part helps explain why social media forums tend to be places where normal restraint against expression overt racist views is not observed (Fielder and Catalano, 2017).

This shift, shaped in part by the affordances of social media has meant that social and political debates have moved away from more clearly articulated ideas to having a rather symbolic nature drawing on buzzwords and often using highly exaggerated boundaries such as between ‘our people’ and ‘others’ (Krzyżanowski and Ledin, 2017: 577). This has been directly related by authors to a demise in forms of politics which favor clearly articulated arguments and a rise of those which favor buzzwords and simplifications (Krzyżanowski and Ledin, 2017). This shift also relates to the growth of a populist notion that politics and policies should be direct, simple, and presented in ways which are immediately graspable (Taggart, 2000), what Wodak (2017) describes as a kind of symbolic politics. This process of simplification and polarization of social and political debate on social media, it is argued, challenges traditional norms of political communication leading to a growth in political expression that is entirely uncivil (Krzyżanowski and Ledin, 2017). Such shifts are said to be lying at the root of the growing trends in ethnic nationalism which are key components to the rising of extreme right-wing populist politics (Rydgren, 2017). This right-wing populism involves fear of losing jobs, declining economic prosperity, instability, of immigration and of the loss of national autonomy and traditions. Most strikingly, it is characterized by an embittered disgust and mistrust of mainstream politics which is thought to be corrupt and non-transparent (Pels, 2012) and which constitutes an elite establishment conspiracy against ‘ordinary people’ (Wodak, 2017). One common strategy used by these political movements is the open scapegoating of immigrants and specific ethnic and religious minorities, such as Muslims, Jews and the Roma as threats to the nation, its culture and ordinary people (Wodak, 2017). Some of the discourses we present from the 1500 comments on the Facebook page must be understood both in regard to these shifting patterns of social and political debate on social media and this rising extreme right-wing populism.

Data and methods

The news-clip we deal with here was originally broadcast in April 2017 as part of a television news bulletin on Romanian Antena 1. It has since been posted and shared across various social media platforms. On YouTube, it was uploaded on different accounts each attracting upward of 100,000 views. The clip was also posted by Rasul (The Laughter), a Facebook-based media company, which brings together humorous material from across the web and social media. The clip received 4.4k reactions, including laughing, likes and anger, 2700 shares and over 1500 comments at the time we were collecting data. In this article, we carry out an analysis of these comments.

In the news-clip itself we see a number of scenes and interviews with the participants. We hear accounts of hiring helicopters, limousines, red carpets, horse-drawn carriages, extremely expensive clothing, entertainment, and lavish honeymoon plans. The editing, used in such reality programs to foreground awkwardness and incompetence (Eriksson, 2015) draws attention to the Roma’s non-standard use of Romanian and creates sequences which make their accounts appear as illogical.

In this article, we draw on MCDA (Machin and Mayr, 2012) to analyze a selection of the 1500 comments posted on Rasul’s Facebook page. As an approach under CDA, MCDA pays close attention to the function of language and other semiotic resources in the social and political life. It is concerned with how various semiotic resources (language, images, emojis, etc.) support particular power interests, legitimize and uphold various inequalities based on race, gender, or access to economic resources (Flowerdew and Richardson, 2017). CDA scholars carry out detailed analysis of texts in order to reveal these interests and how the inequalities are naturalized. A key concept here is that of discourse which is used to describe broader ideas communicated by a text (Fairclough, 2013; Van Dijk, 1993). Discourses can be thought of as models of the world (Foucault, 1977) and can include kinds of participants, ideas, values, goals, and settings (Van Leeuwen and Wodak, 1999). These participants, ideas, values, goals and settings can comprise discursive ‘scripts’ (Van Leeuwen and Wodak, 1999) which are sequences of activity or the ’doing’ of discourses. Such discursive scripts form the accounts of what is going on in the world, who is doing what, for what reasons, with which kinds of priorities. This form of analysis is particularly suited to the analysis of the discursive script which becomes dominant on this Facebook forum to account for the Roma.

The first step of the analysis was to import all 1500 comments into NVivo 12, a qualitative data software, where the coding of the material was manually conducted, and as a result six most salient discourses were identified. The analysis that follows is, therefore, organized into six sections, each section presenting the most salient discourses found in the 1500 posts. The discourses are as follows:

In what follows, we present extracts from the data as we explore how these discourses work and the ideology they carry. The extracts are presented in English and translated from Romanian by one of the authors. Whenever necessary, some explanations are provided in order to reveal what is taking place linguistically.

Illiteracy

We begin with discourse which has been shown to be highly characteristic of representations of the Roma: that they are all illiterate.

In these posts we see direct reference to the level of literacy as in FBC 1: ‘A bunch of illiterates. Having so much money, the bride could have hired a tutor to teach her to speak correctly’. The use of non-standard Romanian by the Roma is directly seen as evidence of stupidity and inferior intelligence: The girl ‘can’t put two words together!’, Oh God, so much stupidity! I am fainting!!!!’, ‘Uneducated Gypsies!’, ‘Oh My God, these ones don’t know how much is 2+2’.

Important in the above comments is that we find statements carrying multiple exclamation marks, pointing to the ‘shared fun’ as in ‘I am fainting!!!!!!!’, ‘I am going to die from laughter!!!!’, ‘Oh God!!!!! Incredible!!!!’. The use of multiple punctuation marks on social media is often associated with the intensity of emotions (Hutto and Gilbert, 2014), where strong feelings, especially in such short posts, are often expressed by repeating letters (e.g. ‘soooooo happy’) or multiple exclamation marks. Zappavigna (2011) also notes that these forms of communication on social media are both about creating affiliations or bonds and providing information.

We see that commentators praise posts which they find particularly funny, which can also be understood in regard to creating bonds on the forum:

Posts also include emojis where laughing-crying icons are inserted in the written comments as seen in Figure 1. Other posts are comprised entirely of hysterically laughing emojis as seen in Figure 2, or of emojis which are vomiting as a response to the lack of taste displayed by the Roma in the film.

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Figure 1.

The use of emojis in comments.

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Figure 2.

Posts comprised only of emojis.

This sense of shared emotion is a central part of the ‘affective connectivity’ (Papacharissi, 2015), which in part drives the engagement and coherence on this Facebook page. Knight (2010) emphasize the important role of humor in developing affiliations where members can become bound by common points of evaluation and by excluding others.

Through the humor here we also see how and evaluation of the relatively higher cultural capital (Bourdieu, 1984) is performed by use of mastery of language through plays on words, paraphrasing and sarcasm. In FBC 2 and 3 above, we see comments parodying the language style of the Roma by mimicking a word urmeste used by one of the participants in the film clip. The word means ‘something is about to happen’, but it is non-standard Romanian grammar. We see this in the comments urmeste to invite you to my wedding’, urmeste the menu of the century… and many other secret surpriza, etc’.

Apart from the non-standard grammar, posters mock and parody errors in logic where participants give an account of the menu and other wedding arrangements. In FBC 2 we find ‘Urmeste’ the menu of the century with limousines and helicopters+the impeccable Florin Salam, truly is known! And many other secret ‘supriza. ⁴ As Eriksson (2015) notes, such reality programing is edited precisely to foreground those errors and awkward moments which point to social incompetence.

The posters use these observed incompetencies to make more sweeping statements about the Roma as a generic class of persons: ‘None of these Gypsies can pronounce a word correctly’, ‘Have you ever seen a Gypsy that can speak correctly?’ It is clear this is not only about the people shown in the news clip itself but about the Roma in general.

The references to the Roma’s linguistic capital include abuse in the form of aggressive statements directed mainly at the bride:

In the first three of these posts the commentators ridicule the bride’s non-standard Romanian and join in with the words ‘urmeste’ and ‘supriza’ to construct a parody which is conceived in aggressive sexualized terms (‘urmeste’ she will suck it a little bit; ‘urmeste’ that I will fuck your throat (about the Roma), and please take it as a ‘supriza’; if she does good tricks with her pussy, she does not need to speak or write correctly). For their supposed stupidity (baby brains, illiterate) it is seen as appropriate to punish them with violent sexual acts and sexual power (IN MY DICK WHERE YOU WERE GIVEN BIRTH). And the bride here, on this day, normally so cherished and sacred across cultures, is represented as a prostitute (tricks with pussy, fuck your throat, etc). The male power communicated by the sexual violence is contrasted with the representation of the groom as a ‘fagot’. Again those postings compete to show mastery in discourse by producing the most outrageous insults.

In FBC 15 we see the degradation of the Roma also carried out through use of an animal metaphor, where the groom is referred to as a ‘crow’, something we found consistently throughout the comments on this Facebook forum. The term ‘crow’ is typical of racist representations of the Roma in Romania. ‘Crow’ points to the Roma being all dark-skinned and non-White, and also carries associations of death, bad luck, and witchcraft. We also see the animal metaphor in the verb used for ‘given birth’ which in Romanian is only utilized in reference to animals; in addition the Roma are referred to as a ‘breed’. Musolff (2015) has drawn the attention to the use of dehumanizing metaphors in relation to aggression toward ethnic minorities. The crow metaphor becomes a substitution for the Roma in the comments and is used for comic affect, for example:

‘this is a wedding with a lot of crows’, ‘the crows are on social benefits’, ‘the crows do not even have two years of education/ do not know how to tie their shoes’.

We also find emoji’s posted as responses which take the form of birds as a sign of bonding and shared humor (Figure 3).

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Figure 3.

Birds and animal emojis used in the comments.

Criminality

Another of the well-documented discourses in the posts on this Facebook page is that Roma are criminal and immoral:

These discourses of criminality have long dominated media representations of the Roma (Creţu, 2014; Fleck and Rughinis, 2008). Here commentators list some of the specific crimes: ‘organ harvesting’, ‘drugs and weapon trafficking’, ‘prostitution’, ‘stealing’, ‘loan sharking’, ‘pimping’, ‘human trafficking’. This is, of course, not a mundane list of crimes, but one which suggests the most sordid kind of travesties against society and against all that is decent. This is also a way the spite and bitterness increase as part of the emotional affect on the page. Those postings are able to bond around these emotive evaluations.

Separate lifeworlds

In the posts, we also find a discourse which represents Romanian society as being divided into two entirely separate lifeworlds. And we find a reversal of roles as some postings represent themselves as a lower class and the Roma as an upper class:

In this discourse we find one world, inhabited by the Romanians, where there is starvation, toil and hardship:

‘don’t have anything to eat’, ‘their hands cracked from so much work’ and ‘we who break our backs and the salary is never enough’.

In this world, as we see in FBC 24 and FBC 25, the earnings from this hard work are given away to the other world, where the Roma spend it on extravagant fairytale weddings, on fashion and other excess – the Roma who are ‘lazybones from their race’. Here the excess and laziness contrasts with the toil and hardship and honest work and payment of taxes. It is the true Romanian people here who are said to be the victims. This is part of a process that Wodak (2015) would call ’victim-perpetrator reversal’ (p.58).

The failure of the establishment

In this discourse the Romanian government and other official institutions are criticized for not dealing with the Roma and, therefore, for failing ordinary Romanian people:

In this sequence of comments, it should be noted that we still find display of mastery over discourse with sarcasm: ‘Oh God, where is the Law 18, did they steal it?’ and ‘Money made illegally and children raised from this money. They will become members of the PSD (Social Democratic Party)’. And such comments are still accompanied by and rewarded with laughing emoticons.

Within these comments we find an expression of bitterness against an establishment which does not deal with the Roma. These posts create a running list of official organizations who are failing to deal with the Roma: ‘Parliament’, ‘National Agency for Fiscal Administration’, ‘National Anticorruption Directorate’, ‘state institutions’ and ‘Social Democratic Party’. Former chief prosecutor of Romania’s National Anticorruption Directorate, Laura Codruța Kövesi, is named specifically.

Such discourses, as observed by Pels (2012), are typical of the new wave of right-wing populism we are seeing in many countries throughout the world. In this discourse, political institutions and the establishment are simply failing to address the interests of ordinary people. And this takes the form of both incompetence ‘the state institutions are sleeping’ and injustice where governments tax hard workers but not the Roma. There is also a clear sense of conspiracy where ‘others’ such as immigrants and ethnic minorities are somehow protected and favored by this establishment (Wodak, 2017) and in this sense the establishment is betraying ordinary people (Rydgren, 2017).

The media are traitors

The media are also represented as being part of the problematic establishment and elite conspiracy. This is hardly surprising given that the media are frequently criticized by right wing-politicians for being too liberal and for not prioritizing the national interests (Wodak, 2019). When in power, such politicians use this idea to legitimize media reforms which serve their own interests:

The verb processes assigned to the media in these comments represent the media as playing an entirely active role: ‘make them celebrities’, ‘promote stupidity and theft’, ‘take bribes from the Roma’. And it is stated that ‘The media is to blame for encouraging the Roma’. Research into media representations of the Roma (Catalano, 2018; Erjavec, 2001; Tremlett et al., 2017) has shown conclusively that they are consistently negative and have been high counterproductive for the Roma. Yet here, they become part of the failing elite establishment acting against the interests of ordinary people. And as we see in the statement ‘Why don’t you show talented people who honored the country’, a characteristic of the right-wing populist script (Wodak, 2017) that the media, therefore, not only fail, but are traitors to the people.

Of note in these posts, as well as earlier posts is that comments address the media (‘what do these people do for you or for the country?’) and the Roma (‘How did you get all that money, you fucking monsters?’). Of course, neither groups are present to reply and these are rhetorical questions. But the direct address brings a sense of agency and confidence to the affective quality of this public. There is a collective sense that together they are taking a stance. As Papacharissi (2015) notes, while such affective publics, may exist here more localized online nodes, we must be alive to how these can provide shoves for more concrete forms of ideological shift.

Extreme racism

We have already seen open racism in these posts where the Roma were substituted for the term crows, along with the use of emojis (Figure 4). But this open racism takes other forms:

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Figure 4.

Emojis posted on extreme racist comments.

We find the use of a White supremacist discourse, seen in FBC 34–37 where we encounter the terms ‘privileged Negros’, ‘coloured’, and ‘monkeys dressed in human clothes’, ‘where you belong, among the jungle trees’. We find emojis and images of apes posted as replies.

In this White supremacist discourse a diverse range of non-European and non-White others are classified together foregrounding as their ignorance, primitiveness, sub-human nature:

The Roma here become classified alongside different ethnicities (FBC 38–41) which are negatively evaluated: Indians, Filipinos and presumably black people from the Congo. In these comments posters are able to display specific and generic racism directed at several other ethnicities as well as the Roma. Here it is foregrounded that the Roma are not part of the pure Romanian ‘Volk’. As Wodak (2019) argues, this right-wing populism promotes the idea of an often nativist, homogeneous ethnic ‘Volk’ (p. 198).

Under the guise of morbid humor (Billig, 2005) along with further attempts to shock, rewarded by emojis, we find a discourse of ethnic cleansing:

FBC 42–51 must be understood in the context of the way that Facebook opens-up the possibility for mixing of humor, venting of frustration and extreme racism as such bonding and affective connectivity takes place. FBC 43 calls out ‘Somebody shoot them!’ Other brutal acts such as ‘burning with petrol’, throwing to the lions’ allude to solutions taken to problem minorities in classical civilizations.

Most striking here is the reference to the Holocaust and to the favorable reference to Ion Antonescu who was the Romanian fascist leader during WWII and a Holocaust perpetrator when around a quarter of European Roma were murdered (Hancock, 1997). Here in FBC 46–50 we see that the poster jibes that if Antonescu were alive ‘You would have so many surprises for them’. Deportation to death camps, torture and genocide are ‘comically’ represented by the euphemism ‘surprises’. The ‘likes’ and feedback is clearly fostering and rewarding extreme references and comparisons which are ‘shocking’ as part of the humor.

Wodak (2019: 189) observes that one part of the right-wing populist script is the notion of a return to better former times as part of a conservative historical revisionism. We see this not only in reference to Antonescu, but also in statements like ‘If Hitler were alive, Romania would be 100 years more advanced’. Here clearly, as in the reference to the Holocaust, there is need for clear, common sense solutions from political leaders who speak for the people and the homeland.

Conclusion

It is well-documented that certain discourses have become established ways of representing the Roma. In the case we explored in this article we found a news-clip posted on a Facebook page inviting and triggering ridicule of the Roma, clearly mindful of these discourses. The news-clip represents what many cultures think of as a happy, romantic occasion: a wedding. Yet the people who post comments take up the invitation to ridicule. They spitefully spit on the event, grotesquely attacking and degrading the participants. We certainly find that the comments carry some of these well-documented discourses. The Roma are described as criminal, dirty, immoral, illiterate and lazy. We also see that the affordances of Facebook open-up the possibility of mixing of humor, venting of frustration, extreme racism and sexual violence as those posting entertain each other, create bonds, ‘bravely’ calling out the Roma, the corrupt political establishment and the traitorous media as they build their affective connectivity. Under the veil of morbid humor and the force and energy of the connectivity they lament their own victimhood and call for simple solutions in the form of ethnic extermination.

Of note is that within this affective connectivity we find an ideology which lacks coherence or clearly formulated arguments. What we find, observed to be highly characteristic of the nature of this rising right-wing populism, is a sense of conspiracy, of which the Roma are a part, against the ordinary decent hardworking Romanian folk. It is countering such conspiracies and the victimhood of the ordinary citizen which is being addressed by right-wing populist political leaders across Europe and the United States. These leaders are not held back by liberal ideas of diversity and equality, but like Ion Antonescu or Adolf Hitler are felt to understand the spirit of the people and provide simple and direct solutions. On this Facebook page we see discourses which are helping to legitimize and foster the scapegoating and brutality against the Roma we are now witnessing across the EU.