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This research explored the difficulties confronting educational policy convergence in the European Union (EU) and developed a working hypothesis on the basis of Luhmann"s (1995) and Lotman"s (1990) theory of social systems and cultural semiotics. It put forward the arguments that (1) policy convergence in education is a complex process of dialogue between multiply coded social semiotic systems, (2) any change in the functioning of social systems cannot disregard the semiotic substrata thatdoi:10.5281/zenodo.3567034 fatcat:karfzjhgl5f4vm55hxmomyqpj4