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Intended parents attend the birth of their child by a gestational surrogate.
Surrogacy is an arrangement, often supported by a legal agreement, whereby a woman agrees to delivery/labour
on behalf of another couple or person, who will become the child's
parent(s) after birth. People may seek a surrogacy arrangement when a
couple do not wish to carry a pregnancy themselves, when pregnancy is
medically impossible, when pregnancy risks are dangerous for the intended mother, or when a single man or a male couple wish to have a child.
In surrogacy arrangements, monetary compensation may or may not
be involved. Receiving money for the arrangement is known as commercial
surrogacy. The legality and cost of surrogacy varies widely between
jurisdictions, sometimes resulting in problematic international or
interstate surrogacy arrangements. Couples seeking a surrogacy
arrangement in a country where it is banned sometimes travel to a
jurisdiction that permits it. In some countries, surrogacy is legal only
if money is not exchanged.
Where commercial surrogacy is legal, couples may use the help of
third-party agencies to assist in the process of surrogacy by finding a
surrogate and arranging a surrogacy contract with her. These agencies
often screen surrogates' psychological and other medical tests to ensure
the best chance of healthy gestation and delivery. They also usually
facilitate all legal matters concerning the intended parents and the
surrogate.
Methods
Surrogacy
may be either traditional or gestational, which are differentiated by
the genetic origin of the egg. Gestational surrogacy tends to be more
common than traditional surrogacy and is considered less legally
complex.
Traditional surrogacy
A
traditional surrogacy (also known as partial, natural, or straight
surrogacy) is one where the surrogate's egg is fertilised by the
intended father's or a donor's sperm.
Insemination of the surrogate can be either through sex (natural insemination) or artificial insemination.
Using the sperm of a donor results in a child who is not genetically
related to the intended parent(s). If the intended father's sperm is
used in the insemination, the resulting child is genetically related to
both the intended father and the surrogate.
In some cases, insemination may be performed privately by the
parties without the intervention of a doctor or physician. In some
jurisdictions, the intended parents using donor sperm need to go through
an adoption process to have legal parental rights of the resulting
child. Many fertility centres that provide for surrogacy assist the
parties through the legal process.
Gestational surrogacy
Gestational surrogacy (also known as host or full surrogacy) was first achieved in April 1986. It takes place when an embryo created by in vitro fertilization (IVF) technology is implanted in a surrogate, sometimes called a gestational carrier. Gestational surrogacy has several forms, and in each form, the resulting child is genetically unrelated to the surrogate:
- The embryo is created using the intended father's sperm and the intended mother's eggs;
- The embryo is created using the intended father's sperm and a donor egg;
- The embryo is created using the intended mother's egg and donor sperm;
- A donor embryo is transferred to a surrogate. Such an embryo may be available when others undergoing IVF have embryos left over, which they donate to others. The resulting child is genetically unrelated to the intended parent(s).
Risks
The embryo implanted in gestational surrogacy faces the same risks as anyone using IVF
would. Preimplantation risks of the embryo include unintentional
epigenetic effects, influence of media which the embryo is cultured on,
and undesirable consequences of invasive manipulation of the embryo.
Often, multiple embryos are transferred to increase the chance of
implantation, and if multiple gestations occur, both the surrogate and
the embryos face higher risks of complications.
Gestational surrogates have a smaller chance of having hypertensive disorder during pregnancy compared to mothers pregnant by oocyte donation.
This is possibly because gestational carriers tend to be healthier and
more fertile than women who use oocyte donation. Gestational carriers
also have low rates of placenta previa / placental abruptions (1.1–7.9%).
Children born through singleton IVF surrogacy have been shown to
have no physical or mental abnormalities compared to those children born
through natural conception. However, children born through multiple
gestation in gestational carriers often result in preterm labor and
delivery, resulting in prematurity and physical and/or mental anomalies.
Outcomes
Among gestational surrogacy arrangements, between 19–33% of gestational surrogates will successfully become pregnant from an embryo transfer. Of these cases, 30–70% will successfully allow the intended parent(s) to become parent(s) of the resulting child.
For surrogate pregnancies where only one child is born, the preterm birth
rate in surrogacy is marginally lower than babies born from standard
IVF (11.5% vs 14%). Babies born from surrogacy also have similar average
gestational age as infants born through in vitro fertilization and oocyte donation;
approximately weeks. Preterm birth rate was higher for surrogate twin
pregnancies compared to single births. There are fewer babies with low
birth weight when born through surrogacy compared to those born through
in vitro fertilization but both methods have similar rates of birth
defects.
Indications for surrogacy
Opting
for surrogacy is often a choice made when women are unable to carry
children on their own. This can be for a number of reasons, including an
abnormal uterus or a complete absence of a uterus either congenitally
(also known as Mayer-Rokitansky-Kuster-Hauser syndrome) or post-hysterectomy. Women may have a hysterectomy due to complications in childbirth such as heavy bleeding or a ruptured uterus. Medical diseases such as cervical cancer or endometrial cancer can also lead to surgical removal of the uterus.
Past implantation failures, history of multiple miscarriages, or
concurrent severe heart or renal conditions that can make pregnancy
harmful may also prompt women to consider surrogacy. The biological impossibility of single men and same-sex couples having a baby also may indicate surrogacy as an option.
Gestational surrogacy
In
gestational surrogacy, the child is not biologically related to the
surrogate, who is often referred to as a gestational carrier. Instead,
the embryo is created via in vitro fertilization (IVF), using the eggs
and sperm of the intended parents or donors, and is then transferred to
the surrogate.
According to recommendations made by the European Society of Human Reproduction and Embryology and American Society for Reproductive Medicine, a gestational carrier is preferably between the ages of 21 and 45, has had one full-term, uncomplicated pregnancy where she successfully had at least one child, and has had no more than five deliveries or three Caesarean sections.
The International Federation of Gynaecology and Obstetrics recommends that the surrogate's autonomy should be respected throughout the pregnancy even if her wishes conflict with what the intended parents want.
The most commonly reported motivation given by gestational surrogates is an altruistic desire to help a childless couple. Other less commonly given reasons include enjoying the experience of pregnancy, and financial compensation.
History
Having
another woman bear a child for a couple to raise, usually with the male
half of the couple as the genetic father, has been referenced since the
ancient times. Babylonian law and custom allowed this practice, and a woman unable to give birth could use the practice to avoid a divorce, which would otherwise be inevitable.
Many developments in medicine, social customs, and legal proceedings around the world paved the way for modern surrogacy:
- 1936 – In the U.S., drug companies Schering-Kahlbaum and Parke-Davis started the pharmaceutical production of estrogen.
- 1944 – Harvard Medical School professor John Rock became the first person to fertilize human ovum outside the uterus.
- 1953 – Researchers successfully performed the first cryopreservation of sperm.
- 1976 – Michigan lawyer Noel Keane wrote the first surrogacy contract in the United States.
- 1978 – Louise Brown, the first "test-tube baby", was born in England, the product of the first successful IVF procedure.
- 1985–1986 – A woman carried the first successful gestational surrogate pregnancy.
- 1986 – Melissa Stern, otherwise known as "Baby M,"
was born in the U.S. The surrogate and biological mother, Mary Beth
Whitehead, refused to give up custody of Melissa to the couple with whom
she made the surrogacy agreement. The courts of New Jersey
found that Whitehead was the child's legal mother and declared
contracts for gestational carrierhood illegal and invalid. However, the
court found it in the best interest of the infant to award custody of
Melissa to the child's biological father, William Stern, and his wife
Elizabeth Stern, rather than to Whitehead, the gestational carrier.
- 1990 – In California,
gestational carrier Anna Johnson refused to give up the baby to
intended parents Mark and Crispina Calvert. The couple sued her for
custody (Calvert v. Johnson),
and the court upheld their parental rights. In doing so, it legally
defined the true mother as the woman who, according to the surrogacy
agreement, intends to create and raise a child.
- 2009 – Ukraine, one of the most requested countries in Europe for this treatment, has its first Surrogacy Law approved.
Psychological concerns
Surrogate
Anthropological
studies of surrogates have shown that surrogates engage in various
distancing techniques throughout the surrogate pregnancy so as to ensure
that they do not become emotionally attached to the baby. Many surrogates intentionally try to foster the development of
emotional attachment between the intended mother and the surrogate
child.
Some surrogates describe feeling empowered by the experience.
Although gestational surrogates generally report being satisfied
with their experience as surrogates, there are cases in which they are
not.
Unmet expectations are associated with dissatisfaction. Some women did
not feel a certain level of closeness with the couple and others did not
feel respected by the couple. Some gestational surrogates report
emotional distress during the process of surrogacy. There may be a lack
of access to therapy and emotional support through the surrogate
process.
Gestational surrogates may struggle with postpartum depression and issues with relinquishing the child to their intended parents.
Immediate postpartum depression has been observed in gestational
surrogates at a rate of 0-20%. Some surrogates report negative feelings
with relinquishing rights to the child immediately after birth, but most
negative feelings resolve after some time.
Child and parents
A systematic review
of 55 studies examining the outcomes for surrogacy for gestational
carriers and resulting families showed that there were no major
psychological differences in children up to the age of 10 years old that
were born from surrogacy compared to those children born from other
assisted reproductive technology or those children conceived naturally.
Gay men who have become fathers using surrogacy have reported
similar experiences to those of other couples who have used surrogacy,
including their relationship with both their child and their surrogate.
A study has followed a cohort of 32 surrogacy, 32 egg donation,
and 54 natural conception families through to age seven, reporting the
impact of surrogacy on the families and children at ages one, two, and seven.
At age one, parents through surrogacy showed greater psychological
well-being and adaptation to parenthood than those who conceived
naturally; there were no differences in infant temperament. At age two,
parents through surrogacy showed more positive mother–child
relationships and less parenting stress
on the part of fathers than their natural conception counterparts;
there were no differences in child development between these two groups.
At age seven, the surrogacy and egg donation families showed less
positive mother–child interaction than the natural conception families,
but there were no differences in maternal positive or negative attitudes
or child adjustment. The researchers concluded that the surrogacy
families continued to function well.
Legal issues
The legality of surrogacy varies around the world. Many countries do
not have laws which specifically deal with surrogacy. Some countries ban
surrogacy outright, while others ban commercial surrogacy but allow
altruistic surrogacy (in which the surrogate is not financially
compensated). Some countries allow commercial surrogacy, with few
restrictions. Some jurisdictions extend a ban on surrogacy to
international surrogacy. In some jurisdictions rules applicable to adoptions apply while others do not regulate the practice.
The US, Ukraine, Russia and Georgia have the most liberal laws in
the world, allowing commercial surrogacy, including for foreigners.
Several Asian countries used to have liberal laws, but the practice has
since been restricted. In 2013, Thailand banned commercial surrogacy,
and restricted altruistic surrogacy to Thai couples. In 2016, Cambodia also banned commercial surrogacy. Nepal, Mexico, and India have also recently banned foreign commercial surrogacy. Surrogacy is legal and common in Iran, and monetary remuneration is practiced and allowed by religious authorities.
Laws dealing with surrogacy must deal with:
- Enforceability of surrogacy agreements. In some jurisdictions,
they are void or prohibited, and some jurisdictions distinguish between
commercial and altruistic surrogacy.
- The different issues raised by traditional and gestational surrogacy.
- Mechanisms for the legal recognition of the intended parents as the
legal parents, either by pre-birth orders or by post-birth adoption.
Although laws differ widely from one jurisdiction to another, some generalizations are possible:
The historical legal assumption has been that the woman giving
birth to a child is that child's legal mother, and the only way for
another woman to be recognized as the mother is through adoption
(usually requiring the birth mother's formal abandonment of parental
rights).
Even in jurisdictions that do not recognize surrogacy
arrangements, if the potential adoptive parents and the birth mother
proceed without any intervention from the government and do not change
their mind along the way, they will likely be able to achieve the
effects of surrogacy by having the gestational carrier give birth and
then give the child up for private adoption to the intended parents.
If the jurisdiction specifically bans surrogacy, however, and
authorities find out about the arrangement, there may be financial and
legal consequences for the parties involved. One jurisdiction (Quebec) prevented the genetic mother's adoption of the child even though that left the child with no legal mother.
Some jurisdictions specifically prohibit only commercial and not
altruistic surrogacy. Even jurisdictions that do not prohibit surrogacy
may rule that surrogacy contracts (commercial, altruistic, or both) are
void. If the contract is either prohibited or void, then there is no
recourse if one party to the agreement has a change of heart: if a
surrogate changes her mind and decides to keep the child, the intended
mother has no claim to the child even if it is her genetic offspring,
and the couple cannot get back any money they may have paid the
surrogate; if the intended parents change their mind and do not want the
child after all, the surrogate cannot get any money to make up for the
expenses, or any promised payment, and she will be left with legal
custody of the child.
Jurisdictions that permit surrogacy sometimes offer a way for the
intended mother, especially if she is also the genetic mother, to be
recognized as the legal mother without going through the process of
abandonment and adoption. Often this is via a birth order
in which a court rules on the legal parentage of a child. These orders
usually require the consent of all parties involved, sometimes even
including the husband of a married gestational surrogate. Most
jurisdictions provide for only a post-birth order, often out of an
unwillingness to force the gestational carrier to give up parental
rights if she changes her mind after the birth.
A few jurisdictions do provide for pre-birth orders, generally
only in cases when the gestational carrier is not genetically related to
the expected child. Some jurisdictions impose other requirements in
order to issue birth orders: for example, that the intended parents be
heterosexual and married to one another. Jurisdictions that provide for
pre-birth orders are also more likely to provide for some kind of
enforcement of surrogacy contracts.
Citizenship
The
citizenship and legal status of the children resulting from surrogacy
arrangements can be problematic. The Hague Conference Permanent Bureau
identified the question of citizenship of these children as a "pressing
problem" in the Permanent Bureau 2014 Study (Hague Conference Permanent
Bureau, 2014a: 84–94).
According to U.S. Department of State, Bureau of Consular Affairs, for a
child born abroad to be a U.S. citizen one or both of the child's
genetic parents must be a U.S. citizen. In other words, the only way for
a foreign born surrogate child to acquire U.S. citizenship
automatically at birth is if they are the biological child of a U.S.
citizen. Furthermore, in some countries, the child will not be a citizen
of the country in which they are born because the gestational carrier
is not legally the parent of said child. This could result in a child
being born without citizenship.
Ethical issues
Numerous
ethical questions have been raised with regards to surrogacy. They
generally stem from concerns relating to social justice, women's rights,
child welfare, and bioethics.
Gestational carrier
Those
who view surrogacy as a social justice issue argue that it leads to the
exploitation of women in developing countries whose wombs are
commodified to meet the reproductive needs of the more affluent.
While opponents of this stance argue that surrogacy provides a
much-needed source of revenue for women facing poverty in developing
countries, others purport that the lack of legislation in such countries
often leads to much of the profit accruing to middlemen and commercial
agencies rather than the gestational carriers themselves.
It has been argued that under laws of countries where surrogacy falls
under the umbrella of adoption, commercial surrogacy can be considered
problematic as payment for adoption is unethical, but not paying a
gestational carrier for her service is a form of exploitation.
Both opponents and supporters of surrogacy have agreed that
implementing international laws on surrogacy can limit the social
justice issues that gestational carriers face in transnational
surrogacy.
Other human rights activists express concern over the conditions
under which gestational carriers are kept by surrogacy clinics which
exercise much power and control over the process of surrogate pregnancy. Isolated from friends and family and required to live in separate surrogacy hostels on the pretext of ensuring consistent prenatal care,
it is argued that gestational carriers may face psychological
challenges that cannot be offset by the (limited) economic benefits of
surrogacy.
Other psychological issues are noted, such as the implications of
gestational carriers emotionally detaching themselves from their babies
in anticipation of birth departure.
The relevance of a woman's consent in judging the ethical
acceptability of surrogacy is another point of controversy within human
rights circles. While some hold that any consensual process is not a
human rights violation, other human rights activists argue that human
rights are not just about survival but about human dignity and respect.
Thus, decisions cannot be defined as involving agency if they are
driven by coercion, violence, or extreme poverty, which is often the
case with women in developing countries who pursue surrogacy due to
economic need or aggressive persuasion from their husbands. On the other end of the spectrum, it has been argued that bans on
surrogacy are violations of human rights under the existing laws of the Inter-American Court of Human Rights reproductive rights landmark.[52]
Some feminists have also argued that surrogacy is an assault to a woman's dignity and right to autonomy over her body.
By degrading impoverished women to the mere status of “baby producers”,
commercial surrogacy has been accused by feminists of commodifying
women's bodies in a manner akin to prostitution. Some feminists also express concerns over links between surrogacy and patriarchal
expressions of domination as numerous reports have been cited of women
in developing countries coerced into commercial surrogacy by their
husbands wanting to "earn money off of their wives' bodies".
Supporters of surrogacy have argued to mandate education of
gestational carriers regarding their rights and risks through the
process in order to both rectify the ethical issues that arise and to
enhance their autonomy.
Child
Those concerned with the rights of the child in the context of surrogacy reference issues related to identity and parenthood, abandonment and abuse, and child trafficking.
It is argued that in commercial surrogacy, the rights of the
child are often neglected as the baby becomes a mere commodity within an
economic transaction of a good and a service.
Such opponents of surrogacy argue that transferring the duties of
parenthood from the birthing mother to a contracting couple denies the
child any claim to its “gestational carrier” and to its biological
parents if the egg and/or sperm is/are not that of the contracting
parents.
In addition, they claim that the child has no right to information
about any siblings he or she may have in the latter instance. The relevance of disclosing the use of surrogacy as an assisted reproductive technique to the child has also been argued to be important for both health risks and the rights of the child.
Religious issues
Different religions take different approaches to surrogacy, often
related to their stances on assisted reproductive technology in general.
Buddhism
Buddhist
thought is inconclusive on the matter of surrogacy. The prominent
belief is that Buddhism totally accepts surrogacy since there are no
Buddhist teachings suggesting that infertility treatments or surrogacy are immoral.
This stance is further supported by the common conception that serving
as a gestational carrier is an expression of compassion and therefore
automatically aligns with Buddhist values.
However, numerous Buddhist thinkers have expressed concerns with
certain aspects of surrogacy, hence challenging the contention that
surrogacy is always compatible with Buddhist tradition. One Buddhist perspective on surrogacy arises from the Buddhist belief in reincarnation as a manifestation of karma.
According to this view, gestational carrierhood circumvents the
workings of karma by interfering with the natural cycle of
reincarnation.
Others reference the Buddha directly who purportedly taught that trade in sentient beings, including human beings, is not a righteous practice as it almost always involves exploitation that causes suffering. Susumu Shimazono, professor of Religious Studies at the University of Tokyo, contends in the magazine Dharma World that surrogacy places the childbearing surrogate in a position of subservience, in which her body becomes a "tool" for another.
Simultaneously, other Buddhist thinkers argue that as long as the
primary purpose of being a gestational carrier is out of compassion
instead of profit, it is not exploitative and is therefore morally
permissible. This further highlights the lack of consensus on surrogacy within the Buddhist community.
Christianity
Catholicism
The Catholic Church is opposed to surrogacy, which it views as immoral and incompatible with Biblical texts surrounding topics of birth, marriage, and life. Paragraph 2376 of the Catechism
of the Catholic Church states that: "Techniques that entail the
dissociation of husband and wife, by the intrusion of a person other
than the couple (donation of sperm or ovum, surrogate uterus), are
gravely immoral."
Many proponents of this stance express concern that the sanctity of
marriage may be compromised by the insertion of a third party into the
marriage contract. Additionally, the practice of in vitro fertilisation
involved in gestational surrogacy is generally viewed as morally
impermissible due to its removal of human conception from the act of sexual intercourse. Anti-abortion
Catholics also condemn in vitro fertilisation due to the killing of
embryos that accompanies the frequent practice of discarding, freezing,
or donating non-implanted eggs to stem cell research.
As such, the Catholic Church deems all practices involving in vitro
fertilisation, including gestational surrogacy, as morally problematic.
Hinduism
As India and other countries with large Hindu populations have become centers for fertility tourism, numerous questions have been raised regarding whether or not surrogacy conflicts with the Hindu religion. While Hindu scholars have not debated the issue extensively, T. C. Anand Kumar, an Indian reproductive biologist, argues that there is no conflict between Hinduism and assisted reproduction. Others have supported this stance with reference to Hindu mythology, including a story in the Bhagavata Purana which suggests the practice of gestational carrier-hood:
Kamsa,
the wicked king of Mathura, had imprisoned his sister Devaki and her
husband Vasudeva because oracles had informed him that her child would
be his killer. Every time she delivered a child, he smashed its head on
the floor. He killed six children. When the seventh child was conceived,
the gods intervened. They summoned the goddess Yogamaya and had her
transfer the fetus from the womb of Devaki to the womb of Rohini
(Vasudeva's other wife who lived with her sister Yashoda across the
river Yamuna, in the village of cowherds at Gokulam). Thus the child
conceived in one womb was incubated in and delivered through another
womb.
Additionally, infertility is often associated with karma in the Hindu tradition and consequently treated as a pathology to be treated. This has led to general acceptance of medical intervention for addressing infertility amongst Hindus. As such, surrogacy and other scientific methods of assisted reproduction are generally supported within the Hindu community. Nonetheless, Hindu women do not commonly use surrogacy as an option to treat infertility, despite often serving as surrogates for Western commissioning couples.
When surrogacy is practiced by Hindus, it is more likely to be used
within the family circle as opposed to involving anonymous donors.
Islam
For Muslims, the Qur'anic injunction that "their mothers are only those who conceived them and gave birth to them (waladna hum)"
denies the distinction between genetic and gestational mothers, hence
complicating notions of lineage within the context of surrogacy, which
are central to the Muslim faith.
Jainism
Harinegameshin Transfers Mahavira's Embryo, from a Kalpasutra manuscript, c. 1300–1350, Philadelphia Museum of Art
Jain scholars have not debated the issue of surrogacy extensively. Nonetheless, the practice of surrogacy is referenced in the Śvētāmbara tradition of Jainism according to which the embryo of Lord Mahavira was transferred from a Brahmin woman Devananada to the womb of Trishala, the queen of Kshatriya ruler Siddharth, by a divinity named Harinegameshin. This account is not present in Digambara Jain texts, however.
Other sources state that surrogacy is not objectionable in the
Jain view as it is seen as a physical operation akin to any other
medical treatment used to treat a bodily deficiency.
However, some religious concerns related to surrogacy have been raised
within the Jain community including the loss of non-implanted embryos,
destruction of traditional marriage relationships, and adulterous implications of gestational surrogacy.
Judaism
In general, there is a lack of consensus within the Jewish community on the matter of surrogacy. Jewish scholars and rabbis have long debated this topic, expressing conflicting views on both sides of the debate.
Those supportive of surrogacy within the Jewish religion
generally view it as a morally permissible way for Jewish women who
cannot conceive to fulfill their religious obligations of procreation. Rabbis who favour this stance often cite Genesis 9:1 which commands all Jews to "be fruitful and multiply". In 1988, the Committee on Jewish Law and Standards associated with the Conservative Jewish movement issued formal approval for surrogacy, concluding that "the mitzvah of parenthood is so great that ovum surrogacy is permissible".
Jewish scholars and rabbis which hold an anti-surrogacy stance often see it as a form of modern slavery wherein women's bodies are exploited and children are commodified.
As Jews possess the religious obligation to "actively engage in the
redemption of those who are enslaved", practices seen as involving human
exploitation are morally condemned.
This thinking aligns with concerns brought forth by other groups
regarding the relation between surrogacy practices and forms of human trafficking
in certain countries with large fertility tourism industries. Several
Jewish scholars and rabbis also cite ethical concerns surrounding the
"broken relationship" between the child and its surrogate birth mother. Rabbi Immanuel Jacovits, chief rabbi of the United Hebrew Congregation from 1976 to 1991, reported in his 1975 publication Jewish Medical Ethics
that "to use another person as an incubator and then take from her the
child that she carried and delivered for a fee is a revolting
degradation of maternity and an affront to human dignity."
Another point of contention surrounding surrogacy within the
Jewish community is the issue of defining motherhood. There are
generally three conflicting views on this topic: 1) the ovum donor is
the mother, 2) the gestational carrier is the mother, and 3) the child
has two mothers--both the ovum donor and the gestational carrier.
While most contend that parenthood is determined by the woman giving
birth, a minority opt to consider the genetic parents the legal parents,
citing the well-known passage in Sanhedrin 91b of the Talmud which states that life begins at conception. Also controversial is the issue of defining Judaism in the context of surrogacy. Jewish Law states that if a Jewish woman is the surrogate, then the child is Jewish.
However, this often raises issues when the child is raised by a
non-Jewish family and approaches for addressing this issue are also
widely debated within the Jewish community.
Fertility tourism
Some countries, such as the United States, Canada, Greece, Ukraine,
Georgia and Russia, are popular surrogacy destinations for foreign
intended parents. Eligibility, processes and costs differ from country
to country. Fertility tourism for surrogacy is driven by legal
restrictions in the home country or the incentive of lower prices
abroad. Previously popular destinations, India, Nepal, Thailand, and
Mexico have all recently implemented bans on commercial surrogacy for
non-residents.