Open Access Journal

ISSN: 2183-2463

Article | Open Access

Multiheaded Federations: The EU and Canada Compared

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Abstract:  The purpose of this article is to assess the merits of comparing the EU and Canada from a federal perspective. The point of departure is that both are federal-type entities that represent deviations from the standard or mainstream American model of federalism. That has given rise to alternative conceptions, multilevel governance for the EU, and a multinational federation for Canada. The article discusses the limitations of each such notion and instead argues for the merits of seeing both as different versions of multiheaded federation which is a useful analytical device for analyzing contestation over federalism within federal-type entities. This notion directs our attention to those with power and in the position to shape the political system’s federal-constitutional nature and design, which normally happens in the realm of constitutional politics. It is the fundamental struggle over sovereignty within a federal-type structure that gives rise to the notion of a multiheaded federation—there are multiple heads because there is no willingness to accept a hierarchical arrangement. The notion of a multiheaded federation is particularly suitable for capturing (de)federalisation processes and dynamics.

Keywords:  Canada; European Union; federalism; multiheaded federation; multilevel governance; multinational federation



© John Erik Fossum. This is an open access article distributed under the terms of the Creative Commons Attribution 4.0 license (, which permits any use, distribution, and reproduction of the work without further permission provided the original author(s) and source are credited.