When U.S. President Donald Trump
said at a rally in Pennsylvania on Monday that he was up for serving a third, fourth and fifth term in office, some ears surely perked up. The United States president is subject to a two-term limit with each term lasting four years. Yet, discussion about term limits is not unusual in countries that employ them. South Korea and Brazil, whose heads of government Moon Jae-In and Jair Bolsonaro are subject to limits shorter or equal to that of the U.S., have recently had discussions about extending term limits. Those suggestions were met with some opposition, as term limits are seen by many as a mode to keep government power in check and ensure a functioning democracy.
Yet, almost no European democracies have term limits for their heads of government. Meanwhile, they are quite common in the Americas and Asia. What seems unfair is really a symptom of different styles of government.
European heads of government, like UK Prime Minister Theresa May or German chancellor Angela Merkel, are typically not heads of state. That function is served in many European countries by a ceremonial president, who does stick to a term-limit similar to a U.S. president, or in fewer cases by a monarch, also with exclusively ceremonial powers. Prime ministers and chancellors are also not elected directly and are therefore dependent on upholding a majority in their respective parliament or throw in the towel. It is also expected that prime ministers and chancellors might face multiple reelections on short notice, in the case of a government dissolving or withdrawing support for its leader. Term limits therefore would be hard to formulate, while toppling a leader remains rather easy. Neither of those characteristics apply to U.S. presidents or their counterparts in Asia and Latin America bringing in term limits as an additional safeguard for leaders who are heads of state and heads of government at the same time.
France is the exception in Europe, with President Emmanuel Macron running the country and government to a large degree. Russia has seen Vladimir Putin and confidant Dimitri Medvedev play a game of musical chairs between presidential and prime minister positions to avoid term limits. China, finally, removed term limits for President Xi Jinping in 2018, while none are put on the prime minister either. The most valuable office in China, Secretary of the Communist Party (also held by Xi), has had no term limits since 2017.