A new Gap ad campaign featuring a young girl wearing a hijab has received a warm welcome in the United States. Social media users like Hamdia Ahmed, the first Miss Maine pageant contestant to wear a hijab, treated it as a welcome sign of diverse representation in media.

But the same image has been stirring up controversy in France—highlighting a fundamental difference in the way the US and France conceive of religion and personal liberty.

The controversy over the girl in the hijab

The campaign, which touts Gap’s “back-to-school” collection, features a diverse group of kids from an elementary school in Harlem, New York. So far, it’s only been released in the US and the United Kingdom, and Gap has not announced any plans to release it in France. But that hasn’t stopped members of the French government on both the right and the left from being extremely vocal about the ad.

On Aug. 11, Aurore Bergé, a French MP and the spokesperson for the centrist party La République en Marche, tweeted: “Nothing justifies or authorizes the veiling of little girls! And today, Gap makes it a commercial argument under the pretext of an ode to diversity.” She told Le Monde: “Starting the year off on the right foot means not putting one in Gap anymore.”

Other politicians have also called for a boycott of the brand. Anne-Christine Lang, an MP from La République en Marche, said she would never go to Gap again. Agnès Thill, another LREM MP who sits on the national commission for education and cultural affairs, tweeted, “This advertisement is an insult to childhood … No hijab in our secular schools.” And Lydia Guirous, the spokesperson for the right-wing party Les Républicains, accused the brand of “submitting to Islamism.”

“I have denounced several times the rise in power of the veil imposed on little girls, which is a form of abuse and a trampling of our values of equality, freedom, and secularism,” Guirous wrote on Twitter on Thursday.

Meanwhile, a petition started by French users on change.org that calls for Gap Europe to disassociate itself from the GapKids campaign in the US has garnered close to 8,000 signatures.

The role of the hijab in France’s history of secularism

The French pushback over the image of the girl in the hijab should be understood within the context of the country’s history of bans on the veil and other forms of religious garb. Secularism, or laïcité, has been enshrined in French law and political practice since 1905, after the French Revolution and decades of tensions between the French Republic and the Catholic Church. The modern French Republic implemented the principle of religious neutrality in schools and other public places to ensure that religion would never again supersede the government, and that all children would have a national identity free of the constraints of religion.

But it wasn’t until 2004 that France passed a law to limit the use of veils and other religious signs deemed “ostentatious” in public spaces. The 2004 secularism law, as it is known in most of the English-speaking world, states that “In schools, colleges and public high schools, the wearing of signs or dresses by which students ostensibly manifest religious affiliation is prohibited.” That included yarmulkes, large Christian crosses, Sikh turbans, and Muslim veils.

France is far from the only European country that has imposed a legal limit on Muslim women’s clothing. Germany, Belgium, Denmark, and Austria have all instituted full or partial bans on face-covering Islamic veils, and the European court of human rights had upheld France’s burqa ban in the face of legal challenges.

Along with religious concerns, another reason for the bans stems from some Europeans’ opinion that the Islamic mandate for women to cover themselves in public is sexist and patriarchal. That belief was evident in 2016, at the height of the “burkini” scandal in France, when police officers were fining Muslim women left and right for wearing the Islamic-friendly full-body covering at the beach. Here is the French ambassador to the United States, Gérard Araud, encapsulating that view:

In theory, French secularism is meant to apply to all religions. But, in practice, Islam is often the target of these policies—far more so than French Christians or Protestants, for example. As Tara Golshan has written in Vox, “This approach of secularity was relatively easy to enforce when France was a more homogeneously Christian country, but France today is much more ethnically and religiously diverse, and the modern interpretation of this belief has proven to disproportionately target Muslims and other minority religious communities in France.”

Critics in France and abroad say that the country’s focus on the veil both arises from and furthers bias against the country’s roughly 8 million Muslims. Rather than promoting a sense of secular inclusion, they argue, laws limiting veiled women’s access to public and community spaces have encouraged rampant discrimination against Muslims in general, and Muslim women in particular.

Statistics collected by the National Observatory Against Islamophobia show that veiled women are disproportionately the targets of Islamophobic attacks in France. In a 2017 report (pdf) written by the watchdog group, Kawtar Najib writes:

Because they are more visible and more vulnerable, veiled women are the perfect targets of anti-Muslim motivations. They are, in fact, the first victims of Islamophobic acts in many countries and especially in France, where there are too many abusive (and therefore illegal) interpretations of the law of March 15, 2004, which prohibits religious symbols in schools.

Moreover, in the wake of several major terrorist attacks perpetrated by Islamist terrorists, anti-Muslim sentiment has been on the rise in France, along with the political power of the far-right. Some say the far-right has weaponized secularism as a tool to defend the traditions of French national identity against what many see as the growing influence of the Muslim population.

Many Muslim women in France feel that the laws are a form of discrimination—a reminder that their home country refuses to accept them as they are. “We women are psychologically exhausted,” a French Muslim told Z. Fareen Parvez, an assistant professor of sociology at the University of Massachusetts Amherst. Another woman told Parvez that her employer allegedly fired her for wearing her headscarf, warning her, “You will never be accepted here.”

Why some French people are boycotting Gap’s new ad

The pushback in France against the Gap ad also arises from the idea that children in particular should not be made to wear the veil. The American ideal of personal religious freedom means allowing every person to make their own choices. But the French conception of personal liberty is more concerned with protecting people’s freedom from religion. The idea is that people should be “free to believe or not to believe, to practice or not to practice, but, in any case, without imposing it on others,” as mathematician and economist Frédéric Saint Clair has written.

That means protecting French children who are not yet old enough to make educated decisions for themselves from adults imposing a religious practice, like wearing the hijab, onto them. That doesn’t just apply to Muslim kids. A recent government directive asked schools to crack down on students who wear ankle-length skirts or hair wraps, often worn by orthodox Jewish girls, as well as kippahs in schools.

More broadly, the controversy over the Gap ad speaks to a deep fear that the American model of multiculturalism, which is antithetical to laïcité, is creeping into French daily life. Céline Pina, a columnist for the right-wing newspaper, Le Figaro, writes: “What really bothers us is that the Gap Kids campaign shows us that Islamists have managed to impose their identitarian symbols … in multiculturalist countries, to the point that the best allies in their offensive against equal rights and secularism are now in the United States.”

The incident also highlights the differences in how Americans and Europeans tend to conceive of the role of parental rights, as opposed to state’s rights, in determining children’s upbringing. As The Economist writes about the debate surrounding hijabs in schools in the UK, “What one camp would consider parental freedom, another would see as infringing the rights and welfare of a child.”

The limits of France’s #BoycottGap campaign

The Gap ad campaign does not violate French laws governing secularism. The principle of religious neutrality applies only to public places and public officials. A private company can craft its own marketing campaigns as it sees fit. And the Gap campaign hasn’t been released in France anyway.

Perhaps the most interesting facet of this controversy is that it has exposed how differently a message crafted for an American audience can play from a French point of view. Many US-based Twitter users praised the Gap campaign on social media, sharing their stories to explain why representation matters, and especially for little girls.

When faced with the same advertisement, many Americans see an ode to diversity and an effort at representation. The fact that some French people instead see gender inequality, religious oppression, and the trampling of national values speaks to the gulf between the two countries—as both attempt to address modern questions about assimilation and integration from completely different vantage points.