European integration through the eyes of ASEAN: Rethinking Eurocentrism in comparative regionalism

The EU in comparative regionalism

The theoretical study of regionalisms seeks to develop some form of generalization or typology for the various regionalisms to be found around the world. Yet this endeavor has yielded few fruits so far (Genna and de Lombaerde, 2010). Despite edited volumes bringing together experts specializing in different regionalisms, inviting each to write about his or her regionalism within a shared theoretical framework, in reality there are also those in which the various chapters lack any connection to the theoretical insights elaborated on in the prefaces and concluding remarks (Fioramonti and Mattheis, 2015: 677). Despite a growth in research, it is true of comparative regionalism at present that few results have been produced in the way of theory construction.

One reason why comparing regionalisms might pose difficulty is that “regionalism” is too broad a term (Sbragia, 2008: 30; Genna and de Lombaerde, 2010: 591). Regionalism has been defined as “a primary state-led process of building and sustaining formal regional institutions and organizations among at least three states” (Börzel and Risse, 2016b: 8) and as “a comprehensive muldimensional programme, including economics, security, environmental and many other issues” (Hettne, 2003: 24–25). The problem is that these definitions are derived from membership in the same region, rather than from an area of cooperation. Thus, regardless of whether the area of cooperation is security (alliances, cooperative security, or collective security), the economy (trade, finance), or the environment, they all fall into the category of regionalism.

Another reason is that there are differences in how researchers deal with the EU, which is an issue also central to this paper. Put differently, this is the issue of whether or not to treat the EU as a model. As regards theory of regionalism, the framing of the EU has changed greatly over time. The neofunctionalist theory that was fervently advocated during the first wave of regional integration theory had emerged from a context that assumed the EU as a model (Haas and Schmitter, 1964; Schmitter, 1970). Regarding its applications to other regions, researchers never went further than verifying whether what was happening in Europe was also happening elsewhere. For example, one characteristic of Asian regionalism that is often pointed out is that it is “loose,” while African regionalism is labelled as “failed” (Söderbaum, 2012: 51). However, these designations strictly originate from comparisons with the EU. What lies behind these characterizations is either a “functionalist bias” or a “pro-integration bias” (Börzel, 2017: 477–478). What is meant here is a bias toward the idea that it is desirable to have a situation in which further integration leads to the solution of problems.

In contrast with this thinking, there is a strong inclination in the second wave of regional integration theory not to frame the EU as a model (Acharya, 2016; Warleigh-Lack and Rosamond, 2010; Söderbaum, 2003: 4; Breslin and Higgott, 2000: 34). This second wave of regionalism research exhibits a much broader range of approaches than did the theories employed during the first wave. Yet, while not nearly homogeneous, the second wave seeks to break free from EU-centrism (not deriving theory inductively from the EU experience). What lies behind this is a concept of integration that can be expressed as “more formally institutionalized regional groups do not necessarily produce more effective cooperation” (Acharya and Johnston, 2007b: 268). Thus, instead of measuring success based on whether or not a region has continued to integrate along the EU model, success is measured according to whether or not the objectives set by each type of regionalism have been achieved (Acharya, 2016: 110).

Yet breaking free from EU-centrism also meant the loss of a reference point when talking about regionalisms. There is no longer any common language within the field of comparative regionalism. Moreover, in actual fact, there is no denying that the EU stands out in terms of its level of integration (Rosamond, 2009: 119). This has become apparent also from research that has attempted to quantify integration levels (Hooghe and Marks, 2015). As such, the EU, being a so-called outlier, has now become a big hindrance to the construction of general theory. Even if we decide to view the EU not as a model but as one case, it stands out to such an extent that devising a general theory to encompass it becomes exceedingly difficult.

Additionally, some EU researchers argue that the EU is a system of government sui generis, incompatible with the work of comparative study, or that it should be compared to states (rather than regionalisms) (Hix, 1994; Wright, 2011). Moreover, there is also a view that understands the regions being investigated by comparative regionalism studies as separate and independent of EU studies. Thus, they have already ceased to situate themselves within the EU-centric “regionalism” universe (Sbragia, 2008: 33). As a result, a “divide” has emerged between EU studies and comparative regionalism studies (Krapohl and Fink, 2013: 472). Seen from such a viewpoint, it becomes inappropriate even to include the EU in the realm of comparative regionalism.

The EU as seen by other regions

Even so, there has been research on the issue of subjectivity—that is, on how non-EU actors perceive the EU. First, there is the research on the EU image (Chaban et al., 2013; Keuleers, 2015). Such research looks at non-EU perceptions of the EU by examining data from opinion polls and interviews. While this comes close to the concerns of this paper, it does not necessarily clarify whether the EU has become a model for other regions, and neither does it clarify historical changes, since most of the data is from after the year 2000. Second, inter-regionalism research—that is, analyzing what kinds of cooperation have developed between regions—has gained in popularity in recent years (Doidge, 2011). Third, there is research on the EU as a normative power (Manners, 2002). This can be said to have added a new layer of analysis by examining the EU concept outside of Europe and the role of the EU in world politics. Nonetheless, neither of these approaches has elucidated empirically how the EU is subjectively perceived by other regions.

Fourth, there is research on regionalism diffusion—that is, the argument that EU institutions and policies spread to other regionalisms (Risse, 2016; Duina and Lenz, 2016). It is true that similarities can be found between the EU and many other regionalisms when it comes to alias laws and courts, meaning that there is a tendency toward policy diffusion from the EU to other regionalisms. However, the underlying mechanism for the diffusion has not been adequately elucidated. Since this paper takes the approach of examining the subjective viewpoints of relevant actors, it will also be able to identify the mechanism for diffusion.

Above, I have outlined previous research on the theme of how the EU is seen by other regions. Lastly, I want to discuss ASEAN and the EU, a major object of analysis in this paper. Both ASEAN and the EU are representative regionalisms, but have been held to possess dissimilar characteristics, enough to frame the two as existing in a relationship of marked contrast (Kahler, 2000). It is true that a great number of differences can be pointed out. Yet, among all the differences, the one most frequently noted is the difference in levels of institutionalization. Here I want to measure institutionalization using the two indicators “pooling” and “delegation” (Börzel and Risse, 2016b: 7). The former refers to “sharing the capability of making decisions among governments through a process of qualified majority rule” (Keohane and Hoffmann, 1991: 7). The latter refers to “a conditional grant of authority from a principal to an agent that empowers the latter to act on behalf of the former” (Hawkins et al., 2006: 7). Either of these indicators point to the EU as more institutionalized than ASEAN, and this often becomes a reference point when thinking about the EU as a model for ASEAN. In other words, the formal, supranational, and highly institutionalized EU is “advanced,” while the informal, sovereignty-adherent, and less institutionalized ASEAN is “lagging behind.” ¹ On the other hand, there are those who argue that the less institutionalized ASEAN suggests an alternative model to EU-style regional integration (Acharya and Johnston, 2007b: 268). The informal institutions seen in ASEAN, known as the “ASEAN Way,” are then held to be different from, yet superior to, those of the EU. It is claimed that a low level of institutionalization does not necessarily lead to ineffectiveness and that it is viable to think of the ASEAN model of low-institutionalization regionalism as another model for success.

The above is an objective analysis of how researchers assess the degree of institutionalization of ASEAN. Now, I turn to the issue of how ASEAN views European integration. There are studies that examine the subjective aspects of this issue (Jetschke, 2009; Wong, 2012; Chaban et al., 2013; Murray and Moxon-Browne, 2013; Murray, 2015; Allison, 2015). One of the focal points of these studies—especially in light of the structural reforms completed by ASEAN through the ASEAN Charter that was signed in 2007—is whether ASEAN was influenced by the EU. Even assuming that these structural reforms did indeed take the institutions of the EU into consideration, there is still debate over whether the intention was to actually move toward an EU-style institution or whether the intention was simply to utilize the proven effectiveness of a system that only superficially resembles the EU.

In the context of this paper, I believe that two views of such studies are essential. The first is a dynamic perspective. Specifically, ASEAN’s understanding of European integration has undergone major changes since its founding in 1967. Nevertheless, previous studies have described a view of the EU held by ASEAN that isolated an analysis of a particular historical period (especially the period immediately before and after the ASEAN Charter) without placing this period in the context of ASEAN’s changing view of the EU. In contrast, this paper conducts a systematic and comprehensive analysis of ASEAN’s perceptions from its founding until the present day. The second is the issue of differences between the various fields. What I would like to emphasize in this paper is the fact that ASEAN’s understanding of the EU differs greatly from one field to the next. From the perspective of the field of functional cooperation that sees ASEAN mainly as an economic cooperative, institutionalization is viewed as a rational idea, and in this context the EU can be held as a “model.” However, from the field of security, it is more rational for ASEAN to operate informally (the ASEAN Way). In this context, ASEAN’s understanding of the EU cannot be lumped together as a single view, and therefore it is extremely important to remain aware of the differences between the fields.

Finally, I would like to provide a concrete definition of the term “model” as it is used in this paper. I have used Wong (2012) as a reference regarding this point. Wong understands the EU as a model in terms of its “model power,” and therefore views it as a type of “soft-power attraction or emotional affect,” which is another way of simply saying “soft power” (Wong, 2012: 670). This is in contrast to the view of it as a “reference point,” which differentiates it from the “rational, utility-maximizing calculations of the actor.” Thus, for ASEAN, the EU does not have “model power” but rather is a “reference point.” This is an easily understandable definition, and I agree with the assertion that the EU does not necessarily function as a soft power. However, when the term “model” is used in this paper, I do not limit its meaning to soft power. When it is determined through the “rational, utility-maximizing calculations” of actors that it is good to introduce a system such as the EU’s, the EU functions as a “model” for ASEAN, and I use the term with this meaning in mind. That is, I determine whether it is functioning as a “model” based on whether or not it is useful in promoting the benefits of ASEAN member countries and not based on whether or not it has some emotional attraction. Therefore, in many of the statements quoted below—for example, even if the interested parties do not specifically use the term “model,” if they mean that it is rational to develop institutions similar to those of the EU and thus ASEAN should change in that direction—I understand that they mean that ASEAN sees the EU as a model. Thus, I do not refer to the EU as a “model” in cases—such as the ASEAN Inter-Governmental Commission on Human Rights (AICHR) and ASEAN’s Parliament—in which an institution that resembles the EU in some way was adopted only because of external pressure (Katsumata, 2009; Rüland and Bechle, 2014). This is because ASEAN itself did not view this as a rational move that would be beneficial to itself.

This use of the term “model” is not an unnatural usage of the word. The main objective of this paper in regard to the issue of whether the EU functioned as a “model” for ASEAN is to empirically indicate the fact that when the word “model” has been used in this way, I recognize that there has been chronological dynamism and differences according to field in ASEAN’s view of the EU, as mentioned above. In the following sections, I will elucidate the changes in perception and the contexts in which they took place, carefully going through the sources.

ASEAN activities in this period

ASEAN is a regional organization founded in 1967 by Indonesia, Malaysia, the Philippines, Singapore, and Thailand. At the time, all of the founding member states were facing the threat of growing communist power inside their borders and saw it as their urgent task to realize political stability and economic development. In addition, relations between the five states were extremely confrontational at the time, starting with the antagonism between Indonesia and Malaysia (Weatherbee, 2015). It follows that the five states pursued ASEAN as a framework for stabilizing international relations through neighborly friendship, allowing each to focus on the domestic issue of state building.

Even so, early ASEAN was a simple organization, in essence nothing more than an annual ministerial meeting (of foreign ministers). In concrete terms, it functioned as a facilitator for neighborly friendship only through the maintenance of continuous channels of communication between the foreign ministers and the resulting confidence building.

The goal of regional stability was first achieved, more or less, through the First ASEAN Summit of 1976 as well as the Treaty of Amity and Cooperation in Southeast Asia and the Declaration of ASEAN Concord, adopted at that same summit. That was when the fundamental principles of ASEAN were established, beginning with the peaceful resolution of conflicts in the region and also including respect for national sovereignty, territorial integrity, and non-interference in domestic affairs. Determined to overcome the serious animosity within the region, ASEAN pursued a path of cooperation that prioritized respect for member states’ sovereignty, making decisions on the basis of non-interference and consensus.

Having overcome the hurdle of mutual distrust, ASEAN identified a new area of activity from the late 1970s to the 1980s in response to the Third Indochina War. While the member states would still clash fiercely because of differing positions, they could still show a united front to the world, condemning the Vietnamese invasion of Cambodia and lobbying on the international stage. Thanks to these activities, the hitherto largely unrecognized ASEAN came to be praised as a successful regional organization. By contrast, until this point, close to no visible results had been yielded in the areas of economic cooperation that were launched in the post-1976 period.

Analysis

As shown above, at least until the 1980s, the relevant actors in ASEAN had not viewed the EU as a model to any significant extent. It was true for ASEAN at this time that neither pooling nor delegation were well developed and that it had a low level of institutionalization. Moreover, projects for economic cooperation had yielded close to no results because of clashing national interests. Yet ASEAN’s achievements went beyond an improved security situation in the form of friendly relations and confidence building between its member states, also making it possible for member states to invest resources in domestic economic development, meaning that the association had indirectly contributed to economic development in the region. Thus, ASEAN did not think of itself as an organization inferior to the EU.

A more fundamental difference from the EU is that the stabilization of international relations within ASEAN, more than anything else, had been for the sake of state formation, the realization of domestic order. ASEAN states, at that time, were not only distrustful of each other, but were still in the middle of state building and facing the threats posed by anti-government forces, foremost of which were the Communists. As such, there was a need for focusing on domestic issues and for realizing economic growth in a stable environment, thus securing government legitimacy (Narine, 2004). This was another reason for utilizing ASEAN’s confidence building as a means toward stabilizing international relations. In this sense, ASEAN was first a form of regionalism for the purpose of strengthening national sovereignty, making it perfectly natural that a transfer of sovereignty never became relevant.

Furthermore, the ASEAN Way appears as a valid course of action against this backdrop. The principle of non-interference, which urges the member states to respect each other’s sovereignty, and consensus decision making, as a way to eliminate the possibility of decisions that go against national interests, were valid facilitators for confidence building and overcoming the deep-seated distrust.

ASEAN activities in this period

In this way, until the 1980s, ASEAN had functioned, first, as an arena where member states could meet on a regular basis to build trust and, second, as an actor, as it did during the Cambodian War, when it showed a united front on the international stage. Then, after the conclusion of the Cold War in the 1990s, ASEAN underwent a transformation. In the first instance, ASEAN’s first fully fledged attempt at economic cooperation came at the fourth summit in 1992. There it was agreed to create AFTA (ASEAN Free Trade Area), in which regional tariff rates were not to exceed 5% within a 15-year period starting in 1993. The number of member states also increased, as Vietnam joined in 1995, Laos and Myanmar in 1997, and Cambodia in 1999. Adding Brunei, which had joined after its independence in 1984, ASEAN now covered the whole Southeast Asian region.

Having gone through this dramatic transformation in the 1990s, ASEAN came to set community building as its new aim in the 2000s. Specifically, the Declaration of ASEAN Concord II was adopted at the ninth summit in 2003, declaring that an “ASEAN Community” would be created by 2020 (later revised to 2015), encompassing the three areas of political security, the economy, and socio-culture. Under this banner of community building, ASEAN has moved to deepen cooperation and to reform the organization itself.

The most emphasized of the three areas making up the ASEAN Community is the economy. The building of an economic community signifies the development of regional economic integration. Concretely, it has meant eager efforts to make possible the free movement of everything from goods and services to capital. The goal is to attract more foreign investment.

In 2008, the ASEAN Charter came into effect as an expression of organizational reform. Primarily, this was to reform ASEAN into an organization that more effectively can implement various projects. In concrete terms, the Charter recognized the association as a legal personality, strengthened the authority of the Secretariat, and established permanent representatives.

Perceptions of European integration

Beginning in the 1980s, a change becomes apparent in ASEAN representatives’ references to European integration. When European integration took a leap forward with the Single European Act in 1986, ASEAN expressed concerns that this might have a negative impact on the association. For example, the 1989 Joint Communiqué of the 22nd ASEAN Ministerial Meeting states that “Despite the assurances of the EC the Foreign Ministers expressed concern over the possible adverse implications to ASEAN as a result of the Single European Market in 1992.” Moreover, Indonesian President Suharto stated at the 1990 ASEAN Ministerial Meeting:

But, at the same time, they also carry negative implications for the competitive position and terms of trade of the developing countries. The formation of powerful economic groupings among developed countries, as exemplified by the prospective Single European Market, indeed offers new trade and investment opportunities for ASEAN countries, but may equally impact adversely if such groupings become inward-looking and erect new external barriers. (ASEAN Secretariat, 1990: 8)

It was common in the late 1980s for representatives of ASEAN to view the dramatic developments in European integration as an opportunity but also as a challenge. Yet this perception of European integration as a threat did not endure, disappearing by the mid-1990s.

Another more important development was the emergence of statements calling for ASEAN to learn from the experiences of European integration. An important reason for this was the desire to go beyond the conventional format of ASEAN as an arena and to engage in functional cooperation, which includes economic cooperation. For example, in parallel with ASEAN’s first fully fledged attempt at economic cooperation through the creation of AFTA, the Joint Declaration of Tenth ASEAN–EU Ministerial Meeting (1992) stated that “They welcomed the offer of the European Community to share its experiences from the European economic integration process and to provide technical assistance to strengthen the institutional capacity of the ASEAN Secretariat.” From this, we can surmise that, with ASEAN reaching a stage in which its members wanted to pursue economic integration, it had at the very least become possible to use the experiences of European integration as a model, necessitating institutionalization and European support.

This tendency toward learning from the experiences of European integration for the sake of ASEAN regional economic integration became more apparent in the 2000s, with references to the EU becoming much more frequent after the year 2000. For example, in 2001, Singaporean Prime Minister Goh Chok Tong called on ASEAN to integrate faster and more extensively, arguing for the creation of an ASEAN economic community, and using the phrase “not unlike the European Economic Community of 1950s” (Jetschke and Murray, 2012: 183). This is an exceptionally early statement of ASEAN’s EU orientation, but it is part of the context for the economic sphere.

Moreover, former ASEAN Secretary-General Surin Pitsuwan pointed out similarities between ASEAN and the EU as regards the goal of a single market, saying that:

ASEAN has no plans to set up a large central bureaucracy similar to the one in Brussels. The association’s administrative headquarters in Jakarta has only about 200 employees, including clerical staff and drivers. The European Commission in Brussels has more than 33,000. (Washington Post, 28 August 2012)

Yet, he continued, “ASEAN needs a strong central mechanism so that it can be a driving force.” Furthermore, the 18th ASEAN–EU Ministerial Meeting Co-Chair’s Statement from 2010 states: “Noting that EU integration was much further advanced, the Ministers encouraged EU to share experiences with ASEAN on regional integration.” ⁴ In any case, it is clear that there was an increase in statements identifying the EU as a reference after economic integration had become the focus of ASEAN cooperation.

Yet it was not only words, because after 2003 ASEAN actually began reforming its organization, as illustrated by the adoption of the ASEAN Charter, in tandem with the goal of community building. In fact, with regard to the process of formulating the ASEAN Charter, both the Eminent Persons Committee, in charge of preparing a draft proposal, and the High Level Task Force (HLTF) on Economic Integration, which drafted the Charter, made actual visits to Brussels and other European cities, receiving help in the drafting process. ⁵ In a compilation of writings by HLTF members, nearly half of them also wrote that the EU had been a useful reference (Koh et al., 2009). In this sense, ASEAN’s organizational reforms were carried out while consciously and explicitly using the EU as a reference.

So, what concrete influences from the EU can we see? First, although the structure itself differs, ASEAN’s idea of “three pillars” seems to be inspired by the EU. The ideas of attaining a legal personality and creating a flag and anthem appear similarly EU-inspired. Another obvious EU influence was the establishment of a Committee of Permanent Representatives, a permanent organization consisting of member state representatives stationed in Jakarta. That this institution was created using the EU’s own Committee of Permanent Representatives (COREPER) as a reference was also confirmed in an interview given by ASEAN Secretary-General Ong Keng Yong (Jetschke and Murray, 2012: 185–186).

A more direct example can be found in the European Commission’s official documents on the creation of the ASEAN Economic Community (AEC), wherein it is stated that it would share its experiences upon the request of ASEAN. ⁶ In fact, the EU provided various forms of monetary and technical support, through projects such as APRIS (ASEAN–EU Programme for Regional Integration Support) and READI (Regional EC–ASEAN Dialogue Instrument), as well as helped to build capacity for the ASEAN Secretariat. ⁷

As shown above, once ASEAN came to pursue economic integration, the EU and EU institutions became a model for ASEAN. Yet, even as ASEAN actors declared that they used the EU as a model, we should note that they also expressed reservations. For example, Singaporean Foreign Minister Shunmugam Jayakumar said in his opening address at the 2000 ASEAN Ministerial Meeting that “ASEAN is not a supranational organization like the EU. We must also be realistic, in acknowledging that many factors are beyond our control. But we are not entirely powerless.” ⁸ Surin Pitsuwan has stated that “ASEAN views the EU as an inspiration rather than a model” (Allison, 2015: 149).

Even when we look at post-reform ASEAN today, after the introduction of its Charter, it is true that its level of institutionalization is low compared to the EU. First, although some countries had argued for the introduction of a voting system to the Charter, this met with resistance and did not happen. Second, the scope and role of the Secretariat is as small as before. Third, as regards the mechanisms for conflict resolution, HLTF recommended for the 2004 revision the establishment of an ASEAN Compliance Monitoring Body (ACMB), but this was not adopted. As before, conflict resolution was handled between the governments, rather than by an independent organization. Moreover, the newly established Committee of Permanent Representatives is much less important than the EU’s COREPER, with regard both to authority and to function.

Lastly, I want to touch on institution formation in the human rights area, and specifically the creation of the Intergovernmental Commission on Human Rights, frequently cited as an institutional change born out of holding the EU as a model. It is true that the EU had long argued for the promotion of human rights norms in ASEAN. For example, the Co-Chairs’ Statement of the 19th ASEAN–EU Ministerial Meeting (26–27 April 2012) states that:

The Ministers agreed to strengthen mutual cooperation in promoting and protecting human rights, in particular by supporting the work of the AICHR with emphasis on capacity building. In this regard, they recalled the fruitful visit of the AICHR to Europe in 2011. (Co-Chairs’ Statement of the 19th ASEAN–EU Ministerial Meeting)

Even so, I believe the circumstances here differ greatly from those surrounding the aforementioned functional cooperation. ASEAN considers economic integration an actual policy aim and institutionalization a necessary step toward realizing that integration. As such, the EU has the character of a model of sorts with regard to both aim and means. By contrast, the Commission on Human Rights is touted simply as a selling point for domestic and foreign consumption, expected to bolster the ASEAN regional institution’s legitimacy, rather than to actually improve the human rights situations in each member state (Katsumata, 2009). Supporting this are the studies that have surveyed EU perceptions among elites in the ASEAN region (through interviews, etc.). They all point out that responses such as “I see the EU as a model” and “We should make use of the EU’s experiences” are limited to the area of the economy (and not human rights or democracy) (Chaban et al., 2013; Allison, 2015).

Analysis

In summary, starting in the 2000s, ASEAN has frequently framed the EU as a model and has actually come to receive support from the EU. Yet this basically applies only to the area of functional cooperation, centering on economic integration, with remarks about “the EU as a model” appearing after ASEAN itself had come to promote the idea of community.

If so, why has ASEAN tried to learn from the EU when it comes to economic integration? Yet, here too, the EU and ASEAN are not aiming for the same kind of economic integration. This becomes clear if we compare the EU to the AEC, which was more or less completed in late 2015. With the existence of close-to-zero-tariff states such as Singapore and Brunei, there is no way of realizing an EU-style common external tariff in ASEAN. In addition, unlike the EU, the AEC is not concerned with government procurement and does not aim for a common currency.

Even so, it is also a fact that they have much in common, from tariffs and the removal of non-tariff barriers to service trade and investment liberalization. Most importantly, a certain level of institutionalization is necessary to effectively implement this form of economic integration. The ASEAN Way is useful in the area of security but not in the area of economic cooperation. Consensus, with its low level of shared management, can only establish the goals desired by those most vehemently passive countries. Moreover, if the level of delegation is low, the lack of performance monitoring and sanctions by independent organizations makes commitments non-binding, leading us to expect nothing more than voluntary compliance. Furthermore, the absence of proper mechanisms for conflict resolution is another serious issue standing in the way of reaching agreement. In fact, it has been pointed out that at the time of formulating the Charter, only about 30% of agreements had been implemented (Narine, 2009: 376).

Adding to this argument, I can mention that the ASEAN countries themselves perceive low institutionalization as an obstacle to functional cooperation. For example, already in 1991, the Thai Foreign Minister, Arsa Sarasin stated at the ASEAN Ministerial Meeting that “It is very difficult indeed to achieve such a consensus [and] when it comes to concrete effective cooperation, it is almost impossible.” ⁹ Upon having received this request, we could see reform efforts actually involving institutionalization. This was the introduction of the “Minus X” formula for economic decision making. It is a system unrestricted by the consensus formula, since it flexibly allows for initial implementation by those countries that do agree. Additionally, with regard to the delegation aspect, beyond the strengthening of the Secretariat, ASEAN adopted the Protocol on Dispute Settlement Mechanism in 1996 and further enhanced it in 2004. The aforementioned ASEAN Charter can also be understood in light of this movement toward institutionalization.

Despite this, ASEAN’s institutionalization remains low. The primary reason is that it does not aim for the EU’s degree of integration, which makes it unnecessary. Yet, in addition, ASEAN would not be able to institutionalize even if it needed to. In concrete terms, it is the diversity of ASEAN member states that obstructs further institutionalization. It is said that Southeast Asian countries are highly diverse in everything from ethnicity and religion to language and political system, but the gap is especially wide between the four countries that have joined ASEAN since the 1990s and the rest. Concretely, this is due to differences in economic development and the ability to devise and implement policies—that is, differences in their abilities as states. These two types of diversity stem from different attitudes toward liberalization policies, and relate to different ideas about the extent of economic integration desired within the ASEAN framework and about how strictly agreements should be complied with. In reality, the only countries favorable to any one of these are Singapore, Thailand, and Malaysia. For example, in August 2007, Singaporean Prime Minister Lee Hsien Loong stated that:

Compared to more established groupings such as the EU, ASEAN is still a long away from becoming a fully integrated community. Far more than the European countries, Southeast Asia is characterised by political, economic and cultural diversity rather than natural coherence. ¹⁰

Moreover, ASEAN Secretary-General Lê Lương Minh remarked in a speech that:

While other regional groupings like the European Union continue to serve as an inspiration, recognising the great diversities among its Member States, ASEAN has over the years developed its own distinctive way of regionalism. ¹¹

We can understand from this that the relevant actors also are under the impression that ASEAN cannot institutionalize like the EU because of its diversity.