What is British art? Marcia Pointon thinks the answer should be found in the new Tate Gallery

The Tate Gallery is facing its greatest challenge since the collection opened its doors to the public in 1897. With the acquisition of the former power station at London's Bankside, the Tate's responsibilities have become a matter for public debate.

The question is how to make the best of this unique opportunity. The chance to recreate a national collection, equal in distinction to the Musee d'Orsay, should be thrilling to those who care about the visual culture of Britain. But what is British art? British beef, British soccer hooligans, British government . . . How does British art fit into this list?

"British" is a term that was legally adopted only in 1707 as a consequence of the Act of Union. It describes England, Scotland and Wales as legislatively united in opposition to Ireland, which was a colonial dependency until partition earlier this century. It seems unlikely that any of the original collectors of the paintings now in the Tate would have thought of them as "British art". Robert Vernon (who gave his paintings to the nation in 1847), for instance, is described in the Dictionary of National Biography as having "collected some 200 works by English masters, as well as a few by Continental painters." This formulation follows the tradition established by Bainbrigg Buckbridge in the 1706 "Essay Towards an English School of Painting" and followed even by that lover of Scotland, John Ruskin, who has little to say on British as opposed to English art.

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"British" is problematic, moreover, because individuals think of themselves as English, Scottish, Welsh, Asian, West Country, Yorkshire, Caribbean and so on and because the word British has a complicated etymology. The term British art was forged around 1800 as a consequence of investment in the idea of a united nation, increased awareness of the cultural and military power of a united empire during the wars with Napoleon and, later, in response to cultural competition from Paris and Munich.

A national collection of art is a bridge between the nation state and the imaginative aspirations of citizens as individuals. For each visitor to the Tate what is "British" is something distinctive. I do not suggest that visitors pause on the threshold to ask themselves what is British about the artists whose work they expect to see. But I do think that one might ask: where are the works of Whistler, an artist born in North America, who worked in Paris and London and died in London? (The answer is that most of them are in Glasgow.) These are not merely practical questions of curatorship and management; to treat them as such is to miss the point. We are familiar with the vital importance of cultural spaces for the narration of nationhood. The persistent story-telling that portrays national identity offers us myths of origin that are extremely powerful.

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To understand just how such myths of nation are produced we might consider a sculpture by Charles Rossi, born in Nottingham in 1762 (of parents of Italian origin). Called "The British Pugilist", it was executed in 1828 and purchased by the Earl of Egremont for his purpose-built gallery at Petworth. Rossi had been present at the house of the Scots surgeon Anthony Carlisle when his host showed his guests into the drawing room where, according to another guest, Joseph Farington, "we found Gregson the Pugilist stripped naked to be exhibited to us on acct. of the fineness of his form - he is six feet two inches high - all admired the beauty of his proportions . . . He was placed in many attitudes".

This meeting was succeeded by a second, more elaborately organised, occasion at Lord Elgin's when several boxers were posed nude among the marbles of the Parthenon frieze, which were stored in the house prior to their purchase by the British government and transportation to the British Museum.

The adjective "British" as applied to this heroic statue of a boxer is the key to an understanding of how an artwork can function in the creation of national myths. In "Boxiana" (1812) Pierce Egan stressed both the Greco-Roman origins of the sport, and the view that "the manly art of Boxing, has infused that true heroic courage, blended with humanity into the hearts of Britons, which have made them so renowned, terrific and triumphant, in all parts of the world". Elsewhere he draws a distinction between the Italians who settle disputes with the stiletto and the British who resolve them with a round of fisticuffs. Rossi's statue is inspired by classical sculpture but is nonetheless insistently national and contemporary. An English artist of Italian origins thus produces an object that compellingly narrates the story of contemporary Britain as heir to the artistic achievements and heroism of the classical world; the notion of British is here a deliberately unifying concept, drawing on the strength of a united kingdom against the fragmentation of national difference (Greek, Italian, Scottish).

Portraiture and landscape have been seen as the quintessentially British genres of painting on quantitative grounds: there simply were more exhibited. Here, too, however, it is primarily in relation to other national identities that what is English transforms into the requisite "British".

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Constable's "Hay Wain" depicts a known site in East Anglia (and therefore might be argued to be characteristically English and not British at all) yet it is signed and dated "John Constable fecit, London, 1821", a traditional Latinate, and therefore international, form of signature, with the name of the metropolis undercutting the idea of rural location and stressing the cosmopolitan nature of artistic practice.

Once the painting was in circulation, accretions of meaning endorse these ambiguities. Thus "Landscape Noon" (to use the title under which Constable exhibited his work) was recognised as a masterpiece in Paris rather than in London. In other words, this representation of an English location was launched on its British trajectory first by Constable when he inscribed the name of the capital city on his canvas and subsequently by layer upon layer of interpretation.

The Tate Gallery of British Art will best fit itself to make sense of the contradictory cultural fragments of a past and a present in which differences (language, religion, customs) are paramount if it embraces the notion that British is, and will always be, a synthetic term. It is useless to search for civil-service-style categories such as place of birth, location of studio, nationality of parent. It is not even useful to search for categories of style, as these are always art-historical constructs through which we organise data, and they fluctuate from generation to generation according to the interests of scholars. Subject matter is a more useful category but it could never be all-embracing; one would not wish to define a still life as British according to the origins of the objects represented. Nor does the self-identification of artists provide a rule: the Irish-born William Mulready, for example, always insisted he was an English artist.

If we recognise "British art" as a label of recent origin, one that was useful in defying foreign competition, we may again find it meaningful as a way of re-locating art produced in the British Isles within the wider framework of Europe. There is nothing retardataire about supporting a historic collection of British art: to understand ourselves as European, we must recognise the diverse traditions that make us separate from, as well as a part of, continental Europe. So how is this to be done?

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Gallery displays organise images into narratives; not only aesthetic but also didactic and historically instructive. By self-consciously engaging with questions of national identity, the Tate could declare its commitment to British art as understood historically within a European context. In North American galleries, after all, British art is hung with French, German, Scandinavian . . . It is surely feasible to arrange loans to create a gallery in which difference becomes a creative underpinning concept. This historical display could show us how Carstens and Corot are like and/or different from Constable. In the National Gallery of Scotland, Canova's "Three Graces" standing opposite Reynolds's exquisite female half-length threesome, "The Waldegrave Sisters", instructs us in the nature of visual reciprocation and illuminates a common European tradition. That the work of Reynolds and other British artists was widely known in continental Europe has long been recognised by print scholars but the implications of this have scarcely impinged as yet upon the hanging of British paintings. The moment when Scotland is creating a national gallery of art is precisely the time to explore, through the unique resources of the Tate at Millbank, the complicated and paradigmatic process through which forms of Scottishness are consumed south of the border, whether in paintings by Allan Ramsay in the 18th century, or by David Wilkie in the 19th. If we can understand something of this, we may also comprehend what Holbein brought from Germany or what Turner took to France.

It is time to acknowledge that a North American-inspired, modernist internationalism has little relevance to the historical study of European art. It is time to recognise British art as being produced from English, Scottish, Welsh and Irish art within the context of a wider Europe with whom we have a common cultural heritage, even if part of that heritage has been to proclaim at times our very insularity. To have been in opposition is not necessarily to have been in ignorance; indeed it can be argued that to recognise something as insular requires a knowledge of what lies beyond. The so-called insularity of British art has frequently been ruptured not only by incomers but also by outgoers: the jardin anglais which is found throughout Europe from France to Poland, the French adoption of the English picturesque, the importance of the graphic work of Flaxman across Europe, the enthusiasm for Hogarth's work in France and Germany. The Tate should embrace the paradox - that British art exists but that it can only be recognised through the diversity of a European context - and place that paradox conspicuously on display in the reorganisation of Millbank. To be European, we must recognise ourselves culturally as British; and to be British, we must acknowledge ourselves culturally as European.

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Marcia Pointon is professor in the department of history of art, University of Manchester.