With university top-up charges high on the UK agenda, we look at how other countries aim to finance higher education
Northern European countries have no plans to make students pay fees, believing that higher education is a public good and that the American model of near-privatisation is fundamentally flawed.
But countries in other parts of the European Union have found that tuition fees are acceptable if they do not replace government aid entirely, even for middle-class students.
"There are major cultural differences within Europe," says Hans Vossensteyn, research associate at the centre for higher education policy studies at the University of Twente in the Netherlands. "The Nordics see education as a public task to be funded by government, Britain is closest to the American model of seeing it as an individual benefit to be paid for, while countries like the Netherlands and Austria are in-between."
Countries that do charge, such as the Netherlands and Austria, rule out differential fees believing they will damage access.
Strikingly, countries with the highest university participation rates - 70 per cent and above in many Nordic countries and Finland - have the most generous funding systems, with free tuition and a grant element for maintenance. Sweden is committed to increasing the proportion of poorer students in higher education and recently increased the grant component to 34.5 per cent compared to 6 per cent previously, significantly reducing reliance on loans.
Even countries with tuition fees are unwilling to make students bear the lion's share of costs.
"You cannot talk of fees without adequate student support," says Mr Vossensteyn, and adds that governments have to be aware of the "pain threshold".
The Netherlands was the first country to introduce tuition fees in the mid-1980s when fees were increased by 5-10 per cent a year, accompanied by generous tax rebates for parents and means-tested support for students.
It was not until the mid-1990s when the government proposed a 50 per cent fee hike that protests broke out. Students blocked railway lines, bringing transport to a virtual standstill.
The government had to back down, eventually agreeing a 25 per cent increase over three years. "Tuition fee increases in the Netherlands have been complemented by supplements to the grant," says Mr Vossensteyn. Some 30 per cent of student support is grant-based.
Even middle-class Dutch students are unwilling to get into debt and most take up part-time jobs. Danish and French students show a similar aversion to going into the red to pay their living costs.
A report by the European Access Network released last year found that Europe-wide, grants have the biggest impact on access to university. Not having a grant deters poor students, with loans making little difference.
Dutch tuition fees cover only about a fifth of average teaching costs, so the state still provides a substantial subsidy from taxes. Even in Canada and New Zealand, where tuition fees have long been in place, fees account for 10 to 25 per cent of study costs. This compares to Charles Clarke's proposals to allow universities to charge up to two-thirds of the cost of the average humanities degree.
Austria's swift introduction of tuition fees of e727 (pound;450) per semester (about pound;900 a year) in 2001 has been fraught, with a 20 per cent drop in the numbers entering university, despite a rise in the number of school-leavers.
The larger-than-expected drop in student numbers has embarrassed government ministers. "This shows that even if the fee increase is modest, if you bring it in suddenly it will frighten off a lot of students," says Mr Vossensteyn.
A recent Austrian poll showed 58 per cent opposed to fees and only 36 per cent for them, causing political problems for the government.
In Germany, some universities are introducing the fee idea by charging administrative costs, says Dr Dominic Orr of the Hanover-based University Information Service. The government's higher education bill, passed last year, forbids the levying of tuition fees but it is being challenged in court by several states.
Several states have brought in fees for so-called "eternal students" after six years of study. Baden-Wuerttemburg saw a 20 per cent drop in student numbers since charging pound;330 per semester for those prolonging their studies.