Letter to the members of the Irish Joint Committee on International Surrogacy

The Irish Joint Committee on International Surrogacy has been working fo 4 months and will finalize its recommandations on June 2022.
Listening to their debates proves that nearly all the members and panelists are in favour of surrogacy, wether commercial or restricted. Senator Sharon Keogan tried to share her critical point of on surrogacy with the Comittee members but was not listened to and silenced. 
Together with STOPSURROGACYNOW UK, an ICASM iorganisation member, we tried to provide another point of view to no avail. Therefore we decided to send this letter to the Committee.


To the members of the Irish Joint Committee on International Surrogacy
Houses of the Oireachtas
Leinster House  Kildare St
Dublin 2 D02 XR20 Ireland

Dear Members of the Joint Committee on International Surrogacy,


As an international Coalition, we would like to bring our expertise on surrogacy to the Joint Committee on International Surrogacy.

We feel very concerned about the recommendations that your committee will produce, and we very much fear that it will lead to opening surrogacy in Ireland.

We would therefore draw your attention on the following aspects:

Most of European countries are banning surrogacy for human dignity reasons. Human dignity:  men, women, and children dignity, is a core value in Europe. Recently the European Parliament has condemned surrogacy[1] saying that

  1. “Condemns the practice of surrogacy, which can expose women around the world to exploitation, in particular those who are poorer and are in situations of vulnerability, such as in the context of war; asks the EU and its Member States to pay particular attention to the protection of surrogate mothers during pregnancy, childbirth and puerperium and to respect all of their rights, as well as those of the new-borns;
  2. Underlines the serious impact of surrogacy on women, their rights and their health, the negative consequences for gender equality and the challenges stemming from the cross-border implications of this practice, as has been the case for the women and children affected by the war against Ukraine; asks the EU and its Member States to investigate the dimensions of this industry, the socio-economic context and the situation of pregnant women, as well as the consequences for their physical and mental health and for the well-being of babies; calls for the introduction of binding measures to address surrogacy, protecting women’s and new-borns’ rights;

Whether commercial or so called “altruistic”:

Donor conceives and surrogacy pregnancies are higher risks and is much more dangerous than naturally conceived pregnancies and should be enlisted among violence against women.  Surrogacy causes violence in at least four thematic fields: medical, psychological, legal, economic, in which personal, situational and socio-cultural aspects are intertwined.

The fact that a healthy woman with no desire for a child receives powerful hormonal treatment to get pregnant is in itself medical obstetric violence, insofar as these treatments can have, and often do have, harmful short- and medium-term consequences for the woman’s health. Before and during pregnancy, the woman also undergoes intrusive obstetrical procedures (ultrasound scans, repeated checks), some of which may not be medically justified, but simply required by the commissioning parents.  Several medical studies show the consequences of surrogacy on women’s health.

A study[2] analysing the practice of surrogacy in the Netherlands over a period of ten years shows that the health risks for surrogate mothers are much higher than for ordinary pregnancies: 20.6% of surrogate mothers suffered from hypertension (in France, for ordinary pregnancies, this risk is on average 10%);  higher risk of pre-eclampsia due to IVF procedure, haemorrhage at delivery occurred in 23.5% of cases (this rate is 5% to 10% in developed countries); delivery was induced in 52.9% of situations (the World Health Organisation recommends not to exceed, in general, 10%).

An American study analysing pregnancy and delivery data of 124 American women, comparing their ordinary pregnancies with those they carried in surrogacy (almost 500 in total), shows that surrogacy deliveries have more obstetric complications (gestational diabetes, hypertension, placenta previa) and require more recourse to amniocentesis, as well as antibiotics during labour and caesarean section.

Psychological abuse due to anxiety or depression can also be identified. Psychological distress appears both in the personal accounts of mothers and in studies.

  • the economic dimension of surrogacy is indisputable, in so called altruistic surrogacy the only person who does not receive financial reward is the surrogate mother, but the overall organisation of the practice remains commercial. Altruistic surrogacy remains transactional as ‘expenses’ include a range of living expenses and so surrogacy appeals to women who are struggling financially.
  • surrogacy will inevitably be linked to reproductive exploitation of women either as egg provider or as surrogate mother as it already happens worldwide.
  • surrogacy is a form of sexual reproductive violence against women, which entails a tremendous inequality, as it affects them not only disproportionately, but exclusively.
  • surrogacy crosses ethical boundaries, objectifying women and children and violating human rights. A womb cannot be separated from a body, the whole women and her whole body is involved in surrogacy. From the biological and genetic perspective, motherhood is not substitutable.
  • the best interest of the child is biased, surrogacy create a situation where, before the child is even conceived, the decision to take the child away from its biological mother is already taken, to the exclusive satisfaction of the commissioning parents which amount to buying children. Surrogacy neglects to recognise decades of research on the mother-baby bond.
  • according to international definitions, transborder surrogacy could be described as smuggling children and trafficking in women.

We hope you find this information useful.

Respectfully yours

[1] European Parliament resolution of 5 May 2022 on the impact of the war against Ukraine on women (2022/2633(RSP))


[2] Henrike E. Peters et al., « Gestational Surrogacy: Results of 10 Years of Experience in the Netherlands », Reproductive biomedecine online, vol. 37, no 6, octobre 2018.

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