Two little letters that make a word too far: The EU has as many different interpretations as member states. Calling it a 'union' only serves to highlight its divisions, says Timothy Garton Ash

WHEN is a European Union not a European Union? When it's the EU.

The thing officially known as the European Union since the Treaty of Maastricht finally came into force on the first day of this month, is not a union in any previously recognised sense of the word.

Union is a strong word. The United States of America are joined in a union. The United Kingdom is a union. To be sure, even in these cases the reality has trailed long behind the words. In America, it took a century and a civil war. In Britain, there are very significant groups that do not accept it to this day. Yet the constitutional arrangements clearly are those of a union.

Not the EU. In some respects, the Maastricht treaty obviously does make what we used to call the EC more closely integrated, or, stretching the word slightly, united. That is what all the fuss was about here. Yet even the Maastricht provisions for the EC are, in other respects, provisions for future differentiation rather than unification. This applies not just to the British absence from the social protocol, and the British and Danish opt-outs on monetary union. It applies even more to the positive prescription for monetary union. For this sets criteria and a timetable which several, perhaps even most, states of the union will not be able to meet.

In any case, what certainly has not happened is a fundamental transformation of the inter-governmental character of the Community. Moreover, what distinguishes the EU from the EC is the addition, beside the EC, of two further pillars of inter-governmental co-operation: in foreign and security policy, and in justice and home affairs.

With the Schengen group, and, on a slightly different plane, with the organisation of west European defence, both in the shape of the Western European Union and that of the fledgling Eurocorps, one has further examples of the spread of variable geometry.

One cannot repeat too often that these things called 'European', whether Community or Union, are still only west and south European. A large chunk of Europe has no part in them.

So what is the EU? The German Constitutional Court, in the important judgment that finally permitted the treaty to come into force, characterises the EU as a Staatenverbund. Not a Bundestaat - the federal European state of Chancellor Kohl's dreams and Lady Thatcher's nightmares. Not even a Staatenbund - a confederation. Just a Staatenverbund - that is, well . . . what?

Roughly, a close association of states which, however, as the judgment repeatedly insists, remains inter-governmental, and whose further development is dependent on the approval of national parliaments. In a wonderful piece of legal German, the court says the EU has no Kompetenz-Kompetenz, meaning that it has no competence to determine its own sphere of competence.

Does it matter calling the EU something it isn't? British empiricists don't like it. Some continental idealists do. And they have a point. Words cannot of themselves create realities. But they can help to shape them. Who would deny the contribution of Churchill's words to shaping the British reality of 1940? Who could dispute that De Gaulle's phantasmic evocations of French glory and grandeur helped to restore the real self-confidence of France? Was it not even so with the goal of 'ever closer union' proclaimed in the Treaty of Rome? And even with the goal of a European Union, to which Margaret Thatcher signed up in the Single European Act of 1986.

Noting in her memoirs that she thought this rhetorical flourish a price worth paying for the single market, Lady Thatcher ruefully observes she was wrong: 'The Germans, rightly, saw that the momentum towards their objective of European Union had been resumed.'

But if a continental idealist could point to that success story, indeed to the whole development of west European integration from the Messina conference of 1955 to Maastricht in 1991, then a British empiricist - or pragmatist, or 'realist' - might point to what has happened since.

For is not the widespread popular reaction against the Messina-to-Maastricht model of European integration, most visibly in Denmark, France and Britain, but most recently and most importantly in Germany itself, in part a reaction precisely to the widening gulf between Euro-rhetoric and European reality? And the introduction of the name European Union is a further widening of that gulf.

Rather as John Major sold Maastricht to his party for what it did not contain, so now as we gear up for next year's European elections, he will be selling the EU on the grounds that it isn't what it says it is. Meanwhile, back in Germany, Chancellor Kohl may still be trying to sell it on the grounds that it is what it says it is - which it isn't. Or at least, on the grounds that it will one day become what it says it is, starting with a Franco-German core. But that, precisely, is what remains to be seen.

On balance, this was a word too far. Less would have been more. But no doubt we'll soon get used to it, and gaily say 'EU' with hardly a thought for what it means. Abbreviations are the world's greatest anaesthetic.

Timothy Garton Ash's new book, 'In Europe's Name. Germany and the Divided Continent', is published by Jonathan Cape, price pounds 25.