How Moving Embryos and Gametes Is Regulated Around the World

Every country has its own rules for what a fertility clinic can send abroad, what it can receive, and what has to happen on paper before either can take place. Clinics handle almost all of this directly — checking consent, preparing releasing or receiving paperwork, applying for authorisation where it's required — and Embryo Links coordinates the courier side once that paperwork is in place. This guide starts with what holds true almost everywhere, then works through the specifics for the countries we move material to and from most often.

The Common Thread, Wherever You're Moving From

The countries below cover most of where we move material to and from, and the specifics vary a lot from one to the next. But four things show up almost everywhere, in some form, whatever the country:

A licensed clinic on both ends. Nowhere we looked at allows reproductive material to move between an unlicensed facility and a licensed one — both the sending and receiving clinic need to hold whatever accreditation their own country requires.

Documented consent. Every framework here treats the patient's written, current consent as the starting point for any transfer, not paperwork tacked on afterward.

Government authorisation for the move itself, in whatever form that takes locally — a licence, a permit, a notification to a ministry, an accreditation held by the clinic's own tissue bank. The name changes constantly; the need for some kind of official sign-off doesn't.

A paper trail. Chain of custody, traceability, adverse-event reporting — whatever it's called locally, every serious framework wants a record of where the material has been and who has handled it.

What differs by country is how strict the rules are around donor material, what the authorisation process actually looks like, and how much of it is publicly documented. Where we couldn't find a clear answer, we've said so below rather than guessed.

United Kingdom

UK fertility treatment is governed by the Human Fertilisation and Embryology Act 1990, substantially rewritten by the Human Fertilisation and Embryology Act 2008 and further amended by the Health and Care Act 2022. Section 3 of the Act requires that IVF activity — creating, keeping or using an embryo — only take place at a clinic holding a licence from the Human Fertilisation and Embryology Authority (HFEA), the UK's fertility regulator.

Consent sits at the centre of any transfer. Schedule 3 of the Act sets out what counts as effective consent — written, signed and not withdrawn — before gametes or embryos can be stored, used or moved to another clinic, and since 2022 stored material also carries a ten-year consent-renewal requirement. Section 24 of the Act gives the HFEA power to issue binding directions to clinics on particular matters, including transport and import or export. In practice, the directions a clinic relies on for a transfer are General Direction 0006 (import and export of gametes and embryos), General Direction 0009 (keeping gametes and embryos during carriage between premises) and General Direction 0010 (satellite and transport IVF), together with the HFEA's Code of Practice, which sets out what a sending clinic and a receiving clinic each need to do — confirming identification, preparing documentation, and the receiving clinic confirming acceptance.

There is no separate document called an "HFEA export licence." Most international transfers proceed under the HFEA's standard General Direction route once both clinics have met the requirements; a smaller number of cases go through a Special Direction, which needs the HFEA's prior permission. Either way, the clinic — not the courier — is responsible for meeting the HFEA's requirements; Embryo Links' role is to carry out the physical transport once that paperwork is settled.

European Union

Cross-border movement of embryos and gametes within the EU currently sits under the EU Tissue and Cells Directive (2004/23/EC). Article 9 of the Directive covers the import and export of human tissues and cells, Article 8 requires traceability from donor or patient through to the receiving clinic, and Article 11 requires serious adverse events and reactions to be reported.

A new regulation has been adopted to replace this framework: Regulation (EU) 2024/1938 on substances of human origin, generally known as the SoHO Regulation, formally adopted in June 2024. It defines embryos, sperm, oocytes and reproductive tissue collectively as "reproductive SoHO" (Article 3(3)), and requires any establishment that wants to import SoHO into the EU to hold specific authorisation as an importing establishment (Article 26); exporting establishments must themselves be authorised generally under the Regulation. Traceability (Article 32) and vigilance — reporting serious adverse events (Article 33) — are both carried forward as binding obligations. The Regulation replaces the 2004 Directive on a phased timeline, with full application from August 2027; until then, the 2004 Directive remains the operative law.

Since Brexit, the UK is treated as a third country for these purposes: a transfer between a UK clinic and an EU clinic needs authorisation on both sides, in the same way a transfer to any non-EU country does.

Council of Europe

Beyond EU law, the Council of Europe's Convention on Human Rights and Biomedicine — usually called the Oviedo Convention — sets two principles that shape how every signatory country treats reproductive material. Article 5 requires free and informed consent before any medical intervention, and Article 21 prohibits the human body and its parts from being a source of financial gain, the legal basis behind the near-universal rule that gamete and embryo donation must be non-commercial.

Moving Material Internationally

Separately from the clinical consent and licensing rules above, the physical carriage of a cryogenic shipment is governed by its own set of international transport rules — the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) for road legs, and the IATA Dangerous Goods Regulations (DGR) for air transport.

Bulk liquid nitrogen and dry ice have their own UN classification numbers (UN 1977 and UN 1845 respectively), but these apply to free liquid or solid shipments, not to a properly prepared dry shipper. The MVE SC 4/3 units Embryo Links uses hold their nitrogen fully absorbed into an inert matrix, with no free liquid present. Correctly prepared and closed, this qualifies the tank for IATA Special Provision A152 — a "Not Restricted" classification, exempt from the dangerous goods regime that applies to bulk cryogenic shipments — which is why it travels as cabin baggage with the courier rather than as cargo, subject to individual airline approval for each booking.

Cyprus

Fertility treatment in the Republic of Cyprus runs under the Medically Assisted Reproduction Law of 2015, with the Council of Medically Assisted Reproduction (CMAR) as the licensing and oversight body. Donor eggs and sperm are permitted, must stay anonymous, and donors can only be reimbursed for expenses, not paid. As an EU member state, Cyprus also sits under the EU framework described above, which is what actually governs cross-border movement of embryos and gametes in and out of the country.

Worth being precise about: this is the Republic of Cyprus, in the south — Embryo Links' partner clinic, Cyprus Crown IVF, operates under this system. The Turkish-administered north of the island runs its own, separate regulatory regime, and the two shouldn't be confused.

Czech Republic

Two Czech laws matter here. Act 373/2011 covers the clinical side of assisted reproduction — who can be treated and under what consent. Act 296/2008, which transposes the EU tissue and cells framework, governs the tissue banks and labs that actually handle cross-border movement, and SÚKL (the State Institute for Drug Control) is the regulator responsible for it. Donor eggs and sperm are generally permitted and, by most accounts, mutually anonymous.

The exact paperwork SÚKL expects for an individual export isn't published in detail — worth confirming directly with them or the sending clinic before a Czech-origin transfer is booked.

Greece

Greece has one of the more developed fertility frameworks in this guide, built up over Law 3089/2002, Law 3305/2005 (which created EAIYA, the National Authority for Medically Assisted Reproduction), and several rounds of amendment through to 2024. Donor eggs, sperm and embryos are all permitted, and since a 2022 reform, donors can choose whether to stay anonymous or be identifiable to the child later — it's no longer fixed either way. Storage limits were extended to ten years in the same reform.

Clinics need an import licence from EAIYA to receive material from abroad; the exact paperwork a courier or sending clinic needs to provide isn't published in detail, so it's worth confirming directly with EAIYA or the receiving clinic ahead of a Greece-bound transfer.

Romania

Romania doesn't have a dedicated fertility law — assisted reproduction sits under its general tissue and transplant legislation, with the National Transplant Agency, Romtransplant, accrediting the clinics and banks that handle reproductive cells. Donor eggs and sperm are generally permitted on an altruistic, anonymous basis, though embryo donation specifically isn't addressed by a dedicated rule the way it is elsewhere.

Romtransplant authorisation appears to be the general mechanism for moving material across the border, but the exact process isn't published in enough detail to state as a fixed procedure — confirm directly with Romtransplant or the clinic before relying on a timeline.

Bosnia and Herzegovina

Bosnia doesn't have one national law — the Federation of Bosnia and Herzegovina and Republika Srpska each regulate this separately, and the two entities' rules differ. In the Federation, the law is specific on the one point that matters most for a courier: moving reproductive cells, tissue or embryos in or out of the country is prohibited by default. The one exception is a patient moving their own material for their own ongoing treatment, and even that has to follow a set procedure. Getting it wrong carries a real criminal penalty, not just an administrative one.

Republika Srpska has its own, similarly restrictive law. In practice, any Bosnia-related transfer needs to be framed unambiguously as the patient's own material for their own treatment, and confirmed with the relevant entity's Ministry of Health before anything is booked — this isn't a route to guess your way through.

United Arab Emirates

IVF in the UAE is governed by Federal Law No. 7 of 2019 Concerning Medically Assisted Reproduction, later amended by Federal Decree-Law No. 17 of 2023. The original 2019 law required couples to be married; the 2023 amendment removed that requirement for non-Muslim couples, who may now access treatment unmarried provided they submit a formal lineage acknowledgment, while Muslim couples still need to show marriage documentation. Donor sperm, eggs and embryos remain prohibited for all patients regardless of nationality or marital status, and stored material is subject to a five-year, renewable storage limit. Import and export of reproductive material is regulated under the law, though the precise current mechanism has continued to evolve through the 2023 amendment, so this is worth confirming directly with the sending or receiving clinic and the Ministry at the time of a transfer.

Clinic licensing is split three ways rather than sitting with one authority: the Dubai Health Authority (DHA) for Dubai clinics outside the Dubai Healthcare City free zone, the Department of Health – Abu Dhabi (DOH) for Abu Dhabi clinics, and the Ministry of Health and Prevention (MOHAP) for clinics in the Northern Emirates — Sharjah, Ajman, Fujairah, Ras Al Khaimah and Umm Al Quwain. This licensing regime applies to fertility clinics. Embryo Links, registered as a free zone logistics company in Ajman, is not a health facility and is not licensed under MOHAP, DHA or DOH — the courier side of a UAE-related transfer sits under UAE customs and free zone procedures rather than the health-licensing regime described above.

Oman

Fertility treatment in Oman is governed administratively through the Ministry of Health's Fertility Centre Standards and Regulations for the Private Sector (2017), rather than a single standalone statute. These standards permit only autologous treatment — using the couple's own sperm, eggs and embryos — and do not permit donor gametes. They also specifically prohibit exporting unfertilised eggs out of the country. Medical practice and clinic licensing more broadly, across all specialities including fertility, is governed by Royal Decree No. 75/2019, the general law on the practice of medicine and allied health professions.

Given how tightly Oman's rules are drawn, anyone moving material to or from an Omani clinic should confirm the current position directly with the Ministry of Health and the sending or receiving clinic before relying on any summary, including this one.

Iran

Embryo donation in Iran is specifically covered by the 2003 Act on Embryo Donation to Infertile Couples, with the Ministry of Health and Medical Education (MOHME) as the regulator. Embryo donation itself is clearly permitted, between a married donor couple and a married recipient couple, on a non-commercial basis. Egg donation is also generally accepted, on the basis of a religious ruling rather than a standalone law; the position on sperm donation specifically has been described by Iranian officials as still being formalised.

We couldn't find a reliable source for exactly what paperwork governs bringing material into Iran from abroad — the kind of detail we hold ourselves to documenting carefully for exports from countries like Serbia and the Czech Republic. Where that detail isn't publicly available, we'd rather say so than guess, and recommend confirming directly with the receiving clinic and the Ministry.

Russia

Assisted reproduction in Russia is governed by Article 55 of Federal Law No. 323-FZ (2011), "On the Basics of Health Protection of Citizens," which permits ART for both married and unmarried individuals with informed consent, and separately sets out eligibility for surrogacy. The detailed clinical procedure for ART is set by Ministry of Health Order No. 803n, in force since January 2021.

One change is worth flagging clearly: in December 2022, Russia introduced a ban on surrogacy arrangements for foreign nationals and stateless persons, with a narrow exception for a Russian citizen legally married to a foreign national. This is a genuinely recent, material restriction, and anyone considering a Russia-related arrangement involving a foreign national should treat it as current law rather than assume an older, more open position still applies.

Serbia

Assisted reproduction in Serbia is governed by the Law on Biomedically Assisted Fertilization (2017). Eligibility (Article 25) covers married and cohabiting couples, and, exceptionally, single women who meet the law's legal-capacity and psychosocial requirements. Donor sperm and donor eggs are permitted, not prohibited: Article 41 sets out a regulated donation system run through a single licensed national reproductive-cell and embryo bank, on non-commercial, anonymous terms, with each donor's material going to only one recipient. Embryo donation is permitted under the same framework. Import of reproductive material is generally permitted, not limited to a patient's own material, when it is not otherwise available domestically — again channelled through the licensed national bank, under the traceability and authorisation requirements set out in Article 42. Centres and the national bank both require a government-issued permit to operate.

Spain

Spain has one of the more open fertility frameworks in Europe, set out in Ley 14/2006 on Assisted Human Reproduction Techniques. Article 6 allows any woman aged 18 or over to be a recipient of treatment, regardless of marital status or sexual orientation. Article 5 permits donor gametes, on an anonymous, strictly non-commercial basis, with a national cap of six children per donor. Article 11.4 permits embryo donation as one of several legal options for surplus cryopreserved embryos. Clinics require authorisation under Article 17.

Import, export and traceability of reproductive material are governed separately, by Royal Decree 1301/2006 — which transposed the EU Tissue and Cells Directive into Spanish law — rather than by Ley 14/2006 itself. The Comisión Nacional de Reproducción Humana Asistida (CNRHA) is the national advisory body on assisted reproduction, attached to the Ministry of Health.

Pakistan

Pakistan doesn't have a single fertility law — Islamic jurisprudence is the main framework clinics actually operate under, alongside general bioethics guidance from the National Bioethics Committee. Treatment is generally restricted to a married couple's own eggs and sperm; donor material isn't part of accepted practice.

Pakistan does have national guidelines covering the export of human biological material generally, involving an export licence from the Ministry of Foreign Affairs' Strategic Export Control Division alongside bioethics-committee approval — but whether this is actually the process applied to a courier moving a patient's own embryos, as opposed to research specimens, isn't confirmed. Confirm directly with the sending clinic before assuming a specific process applies.

China

China regulates assisted reproduction tightly, under a 2001 health-ministry regulation that flatly bans buying or selling gametes or embryos, restricts egg donation to uncompensated sharing from a woman's own IVF cycle, and — as a matter of current administrative policy — limits treatment to married couples. Separately, moving human genetic material, including reproductive material, out of China falls under China's human genetic resources regulation, which requires government approval and is administered by the National Health Commission.

This is the one country in this guide where we'd specifically caution against assuming a straightforward process. China treats this area seriously and enforces it, and exactly how the approval process applies to a patient's own clinical embryo shipment, rather than a research sample, isn't something we could confirm from public sources. A China-bound or China-origin transfer needs direct, current confirmation from the clinic and, realistically, local legal advice, not a general guide like this one.

Malaysia

Malaysia has no dedicated fertility law. Clinics work to a Malaysian Medical Council guideline alongside general healthcare-facility licensing, and for Muslim patients, a fatwa from the National Council of Islamic Religious Affairs — which prohibits donor eggs, sperm and embryos, though enforcement of religious rulings varies by state. Where a patient isn't Muslim, the legal position is less clearly documented, since there's no dedicated fertility statute to point to either way.

We couldn't find a specific, named process for exporting or importing reproductive material to or from Malaysia. Confirm directly with the receiving clinic and Malaysia's Ministry of Health before assuming any particular procedure.

Indonesia

Indonesia regulates this by statute — most recently the 2023 Health Law, backed by ministry regulations that were themselves updated in 2025. The law requires that any embryo be created from a married couple's own eggs and sperm and implanted back into the same wife, which in practice rules out donor material and surrogacy alike.

As with several countries in this guide, we couldn't confirm a specific named process for moving reproductive material across Indonesia's border — general import rules exist for other biological material, but nothing we found applies them explicitly to embryos or gametes. Confirm directly with the receiving clinic and Ministry of Health.

Tajikistan

Tajikistan's Health Code (2017) explicitly permits gamete donation and sets out patients' rights to fertility treatment, with the Ministry of Health and Social Protection as the regulator. What the Code doesn't do — and we checked this directly against the statute rather than relying on a summary — is say anything at all about moving reproductive material across the border. A chapter that covers cross-border rules for other tissue types specifically excludes reproductive material from its own scope.

This looks like a genuine gap rather than something we failed to find. Any Tajikistan-related transfer should be confirmed directly with the Ministry of Health and Social Protection before assuming any particular process applies.