Audrey Azoulay 21 March 2023
Dear Ms. Azoulay.
We are writing to you about UNESCO’s guidance document, “Addressing anti-semitism through education: guidelines for policymakers”, and in particular about the paragraph regarding the International Holocaust Remembrance Alliance Working Definition of Antisemitism (IHRA WD), under Defining Antisemitism. While the paragraph lists the countries that have endorsed the IHRA WD and cites the basic definition, we note with approbation the clear statement that neither OSCE nor UNESCO has adopted it. We believe that is the correct policy. We urge you to maintain it.
We agree with the opening comment in the paragraph that the complexity and sometimes contradictory nature of antisemitism has made it hard to define. In fact, the difficulty has been exacerbated in recent years because it has become entangled with the right to criticise Israel. This has arisen largely because the Israeli government and the Israel lobby have been aggressively promoting the IHRA WD, which is biased towards seeing fundamental criticism of Israeli actions as hidden antisemitism.
While criticisms of Israel can be hidden antisemitism, it is equally true that allegations of antisemitism can be hidden attempts to suppress criticism. Educational guidance must provide criteria which distinguishes logically between the two. The IHRA WD does not provide that. It does the opposite.
There are a number of reasons for its shortcomings.
Its provenance is a sure clue to its nature. Despite being taken up by the IHRA, it was actually produced by a very small group of people working for or with big Jewish communal organisations that support Israeli policies.
The core definition is bewilderingly imprecise and fails the first test of a definition, which is to define. It is useless for deciding whether any particular statement is antisemitic.
It creates uncertainty as to whether any given statement criticising Israel is legitimate or antisemitic. Therefore it discourages people from criticising Israel for fear of being called antisemitic.
The 11 illustrative examples are heavily biased towards interpreting fundamental criticism of Israel as antisemitic. Two in particular lend themselves to this, i.e. “Denying the Jewish people their right to self-determination, e.g. by claiming that the existence of a State of Israel is a racist endeavour.”, and “applying double standards by requiring of it [Israel] a behaviour not expected or demanded of any other democratic nation.”
Those two examples are often used to demand cancellation of Palestinian support events where Boycott, Divestment and Sanctions (BDS) against Israel will be advocated, despite the fact that boycott and divestment are traditional means of protest against governments that people consider unjust. The right to advocate them is protected in democratic countries by the right to freedom of expression and peaceful assembly. Since 2015 there have been a total of 27 Court rulings in western countries that advocating BDS is legal.
By adopting the IHRA WD, UNESCO would unwittingly be misdirecting young people towards false beliefs about antisemitism. It would also be undermining the two seminal United Nations declarations on human rights..
The criteria required for UNESCO’s guidance can be provided by the Jerusalem Declaration on Antisemitism (JDA).
The JDA’s provenance gives confidence in its objectivity. It was framed by an international group of eminent academics in the fields of Holocaust history, Jewish studies, Middle East studies and philosophy. They do not all share the same political views and are not seeking to promote a partisan political agenda. It is endorsed by more than 200 scholars from several countries.
It provides a clear definition of antisemitism that enables people to distinguish between statements that are antisemitic and those that are not.
It provides a basis for differentiating logically between legitimate criticism of Israel and criticism which is antisemitic.
It does not create a bias either for or against criticism of Israel.
It supports the legitimacy of criticising Zionism, fundamental criticism of Israeli policy, and advocacy of BDS in protest against Israeli policy.
It is consistent with the right to free speech protected by United Nations Declarations.
To sum up, we urge you to adopt the JDA as the appropriate criteria for UNESCO’s guidance and not to give any credence to the IHRA WD.
We have attached to our covering e-mail a full analysis of the IHRA WD and the JDA, a brief description of our group and the list of 27 Court rulings..
We would be happy to meet you on-line to discuss these issues.
Dror Feiler, Chair of EJJP, Judar for Israelisk-Palestinsk Fred (Stockholm).
Arthur Goodman, Diplomatic and Parliamentary Officer, JFJFP (London)