A Comparison in Adoption – The United States Vs. Europe

While all countries differ in political climates and cultures, the United States can be lumped into a category with other countries that we can generalize as “civilized.” Countries such as Canada, France, Germany, Australia, Ireland and others would all fit into this category as we have similar ethics and cultures in a broad sense of the word. Since domestic infant adoption has been seen as something that is necessary to “save” babies from a life of poverty and no opportunities, thousands of babies, each year, in the United States, are relinquished to adoption from perfectly capable mothers. I was wondering why the babies in this country needed to be “saved” and decided to take a look at other countries, like ours, to see if the same theories and ethics applied, in regards to domestic infant adoption. Certainly, because we are all human beings, the same situations of what we consider a “crisis pregnancy” would exist in other countries. How do other countries handle crisis pregnancies? In America, the solution seems to be adoption, at all times. That is what is encouraged. That is what is socially acceptable as the “selfless and right” thing to do.

First let’s take a look at the number of adoption by country with an image that was borrowed from the United Nations. As you will see, the number of adoptions in America is WILDLY disproportionate to those in other countries of similar cultural values.

The adoption industry, in America, has jumped through enormous hoops over the past several decades to assure that infants become easier to obtain. The focus has been on a cultural acceptance of separating mother and child as the “best” thing to do as well as lobbying Congress with hefty funds that are generated, and then in turn donated, from the adoptions of these children. Do not be fooled; Adoption, even the “non-profit” kind, is a BIG money-maker. The profits are given to other “non-profit” firms (tax-free I might add) who then use those “donations” to lobby for law changes that will assure the easiest road possible to keep the industry running. And as long as there are people who are “in want” of those babies, this is how it will always be. Why is it that a mom can sign away her rights hours after birth in this country? Why the rush? Because it lessens the time period she has to change her mind. Why do most states allow for no revocation period? Because it makes it impossible for her to change her mind. These are not laws that protect mothers and their children. They protect the agency and the agency’s clients – the hopeful adoptive parents. The cycle just keeps going while the adoption machine gets bigger.

France

Domestic infant adoption in France is scarcely heard of these days. In the past 15 years, domestic infant adoption rates have declined 63% while the people wanting to adopt infants domestically has risen 65%.(1) In 2003, 4500 children were adopted in France and only 500 of them were FROM France – and most were not infant adoptions. The rest were adopted via international adoption.(2) Why is this? Certainly if it is thought necessary to save a child from a life of poverty then there must be a reason for the sudden drop of available infants for adoption. Did everyone suddenly become rich or did the cultural thought process behind adoption change? Well, we all know it isn’t the latter. A huge cultural shift that focuses primarily on family preservation has been up and running in France for the past 15 years and it has been widely successful. What about revocation periods in France? The biological parents have TWO MONTHS to revoke consent. That is what is in the best interests of the parents and the child. And probably a big reason adoption rates have declined so much. I cannot find anything about the waiting period after birth before a mother can relinquish her rights and I’m apt to say it’s because no adoption plans are made when a mother is pregnant. It just doesn’t happen this way, as opposed to the U.S. Mothers are encouraged to try parenting and adoption is an option if it doesn’t work out. Another road block to successful adoptions in France is the fact that in must be approved by the parliamentary system. A mother cannot simply sign a piece of paper in a hospital in front of a social worker and her rights are terminated. That is also as it should be. Finally, in France, there are two types of adoption. One is a simple adoption and the other is a full adoption. The simple adoption is most common and instead of severing rights of one set of parents it simply adds to the rights already in place. Adoptive parents are granted full rights and custody to a child in ADDITION to the rights the biological parents already have.(3)

Germany

In Germany, a parent cannot consent to the adoption of their child until the child has reached 8 weeks of age. Similar to France, with their 2 month revocation period, Germany is centered on family preservation and a mother making a truly informed decision. The law allows for her to make sure her mind is fully recovered from having given birth. Also like in France, the courts will have to approve of the adoption plan. A mother cannot simply terminate her rights without the courts approval. Unlike France, domestic infant adoption is sometimes planned during pregnancy, but it is very strictly monitored by the Adoption Placement Act of Germany. This act places regulations on adoption agencies and pretty much outlaws all the standard agency practices that exist in the United States – including advertising. Agencies CANNOT advertise. You can read the full act here if you so wish (4)

Spain

Spain’s adoption practices are very similar to America’s with a few differences. Spain does not consider any consent for adoption given by a mother less than 30 days after birth to be valid. 30 days must have passed since she has given birth before she can consent to the termination of her rights and subsequent adoption of her child. Like France and Germany, a court must approve this decision.(5)

You get the idea. This goes on and on and on for just about every European country. As a matter of fact, international adoption is THE most common form in Europe. Between 70% and 90% of all adoptions come from other countries, not domestically. Consent cannot be given for months and/or can be revoked for months. Let me remind you of that chart from the beginning of this article. The United States allows parents to sign their rights away HOURS after birth and sometimes before. See, I believe that when consent is signed is the key. I believe that a mother cannot fully understand the decision she is about to make without first taking the time to attempt to parent her child.

There will be some who may say, “Well, that may be so. But I’d rather see a child given up for adoption than to live in a home where it will be abused, neglected or unwanted.” Let’s address this, shall we?

The rate of child abuse fatalities in the United States is three times the rate of Germany’s, more than twice the rate of the UK or Japan, and almost twice the rate of France.(6) We can just throw that argument right out the window. Besides, what do you expect from a country who treats children as commodities?

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(1) http://www.uea.ac.uk/swp/icar2/pdf%27s/Halifax99.pdf

(2) https://www.ined.fr/fichier/s_rubrique/18712/publi_pdf2_pop.and.soc.english.417.en.pdf

(3) http://www.uea.ac.uk/swp/icar2/pdf%27s/Halifax99.pdf

(4) http://www.adoptionpolicy.org/pdf/eu-germany.pdf

(5) http://www.adoptionpolicy.org/pdf/eu-spain.pdf

(6) http://www.childabuseintervention.org/child-abuse/statistics