BEIJING – This Winter Olympics, you might notice that nearly three dozen athletes competing for Team China are not Chinese citizens.
Who gets to play for a country's national team at the Winter Olympics is an especially complicated question in China, where issues of identity, ethnicity, and citizenship are at stake.
To be clear: switching teams is extremely common. Countries with long immigration histories, such as the United States or Canada, as well as smaller countries, such as Qatar or Bahrain, have long bolstered their national team rosters with naturalized athletes.
"There's definitely a 'brawn drain' going [on]: basically extracting athletic capital from economically developing nations," says Tom Fabian, a researcher at the University of Ottawa who studies international athletics. "It's been going on for a long time, and it's not just one particular nation."
China is a latecomer to this practice, however. That is because it expressly forbids its citizens from holding citizenship in another country.
So when U.S.-born freestyle skier Eileen Gu announced on Instagram in July 2019 that she would be competing for Team China during the Beijing Winter Olympics, the internet exploded. Many people wondered: had Gu taken a Chinese passport and given up her American one?
So far, she's pointedly avoided answering such questions. "I'm American when I'm in the U.S., and I'm Chinese when I'm in China," she said at a recent Olympic news conference.
China's citizenship laws go back more than a century
Why does China have such strict nationality laws?
The answer dates back to the Qing dynasty, to 1909, specifically – just two years before a massive revolution ended imperial rule in China.
Qing officials implemented China's first nationality law in 1909, establishing the bloodline principle – the idea that citizenship is based on Chinese heritage, and not where you were born.
Ethnic Chinese people living abroad – in Southeast Asia, the U.S., and Europe – were agitating to overthrow dynastic rule in China, so Qing dynasty officials were desperate to co-opt these diasporas and stop them from fomenting revolution.
They drew their inspiration from Japanese nationality law at the time, which also relied on a jus sanguinis principle of citizenship.
"It is really a 20th century phenomenon of Chinese regimes celebrating and reaching out to and seeking connection with so-called overseas Chinese communities," says Tom Mullaney, a history professor at Stanford University.
Controlling citizenship was thus a way of ensuring allegiance to only China. "They assumed a consequence of the bloodline principle would be unconditional permanent loyalty," says Shao Dan, a history professor at the University of Illinois at Urbana-Champaign.
This emphasis on ancestral national identity also came out of a desire to protect Chinese citizens abroad.
Shao says Qing officials wanted to push back against a move in the Dutch East Indies (present-day Indonesia) to deem thousands of ethnically Chinese people in the colony as Dutch citizens. That sparked a flurry of letters petitioning the Qing court to grant those affected Chinese citizenship.
Today, this ethnic heritage approach to nationality continues to allow the Chinese state to perceive diaspora Chinese – even those who hold foreign passports – as fundamentally Chinese in their national identity and a target for political influence operations.
Nationality is more important than citizenship
For athletes deciding which national team to compete for, eligibility comes down to whether athletes profess a Chinese nationality, but not necessarily citizenship.
Here is where it gets even more complicated.
"Citizenship is a much more formal recognition that conveys certain rights on you, whereas nationality does not have that," says Mike Gow, a lecturer in international business at the United Kingdom's Edgehill University. "Nationality is ... more tied up with your identity [and] who you are."
The International Olympic Committee doesn't require that athletes have citizenship to compete on a national team — only that they can prove their nationality.
Establishing nationality can come from living in a country for a certain period of time or demonstrating a personal link to that country through ancestry. For example, the International Ice Hockey Federation allows male athletes, with dual citizenships, who spend at least four years living in one of those countries and playing for their national team to represent that country at international competitions. (Female hockey athletes only need to do so for two years). The IOC also says its board can rule on any exceptional cases in which an athlete wishes to represent a country other than their own.
Around around three-fourths of Team China is comprised of athletes — some with no Chinese heritage whatsoever — who were born in North America and Russia.
So,it is possible foreign athletes born to Chinese parents abroad could declare Chinese nationality in order to play for China – and likely also keep a second, foreign passport.
The IOC confirmed that Gu acquired Chinese nationality in 2019.
"Due process has been followed and the necessary documentation, including a copy of her Chinese passport, was submitted by the Chinese National Olympic Committee. Consequently, Ms Gu is fully eligible, from a nationality perspective, to represent the People's Republic of China at the Olympic Winter Games Beijing 2022," the IOC said in an emailed response to questions from NPR.
According to the Chinese consulate in New York, athletes who obtain Chinese permanent residency can also play for the Chinese national team.
In 2020, China loosened requirements for its permanent residency status – akin to a green card – so that any foreigner with demonstrated talents in economics, science and technology, education, culture, health, and sports was eligible.
Gary Chodorow, a U.S. immigration lawyer who specializes in China, says although only a small number of people have received permanent residency, the policy is a sign that China's rigid views on who counts as Chinese may be relaxing – just a tiny bit.
"Probably the most important factor for the Chinese government is being able to take advantage of the wealth and expertise of overseas Chinese and allowing them to come to China to share what they've got and contribute," says Chodorov.
The law is one thing, but acceptance by the larger Chinese society is another matter.
That seems only to extend to those who are successful.
Zhu Yi, a U.S.-born figure skater on China's team, fell during her first Olympic performance. That blunder, and her rusty Mandarin, caused Chinese internet users to lambaste her for taking a Chinese-born skater's spot.
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