While a number of world leaders lined up to criticize a leaked draft opinion that suggests the Supreme Court is considering overturning a landmark case that legalized abortion, some represent countries that have even more restrictions on abortion than those at issue in the arguments before the court.
The United States is an outlier in the permissibility of its abortion laws in some states.
Few countries allow abortion as late into pregnancy as the U.S. does, and many countries require a woman to produce a reason, such as financial hardship or mental distress, to obtain the procedure past the earliest weeks of gestation.
Besides the U.S., just six other countries permit on-demand abortions past 20 weeks of pregnancy: Canada, China, Netherlands, North Korea, Singapore, and Vietnam.
The debate about a shift in how the U.S. structures its abortion laws has tended toward the emotional, with Democrats warning that a host of other rights could come under threat if abortion does.
But that belies the fact that Americans generally enjoy more access to abortion than a significant portion of the developed world. That would likely continue even if the Supreme Court does uphold Mississippi’s right to enact a ban on abortions after 15 weeks of pregnancy.
A French senator from President Emmanuel Macron’s political party called on “progressives everywhere to mobilize” after the draft opinion in Dobbs v. Jackson Women’s Health Organization leaked.
But France begins to outlaw elective abortions at 14 weeks of pregnancy, one week before the Mississippi law that triggered Dobbs cuts off the procedure.
After 14 weeks, any woman seeking an abortion must have two doctors attest that carrying her baby to term would inflict severe physical or mental harm on her.
For years, the French restrictions were even less permissive.
Until February of this year, French women could not obtain an abortion on demand after 12 weeks of pregnancy.
Doctors in Germany were, until this year, prohibited from advertising their abortion services to women thanks to a decades-old provision.
While Germany’s new government has revised that provision, abortion access is still far more limited in Germany than in the U.S.
Abortions are technically illegal after the first trimester, which ends after 12 weeks of pregnancy.
If a German woman wishes to have the procedure, she must undergo mandatory counseling.
Germany’s law does include exceptions for rape and cases in which the pregnancy presents a grave risk to the health of the mother. But Germany’s abortion laws ban most abortions far earlier in pregnancy than almost every U.S. state.
Scottish First Minister Nicola Sturgeon argued the right to abortion is a “human right” after the Dobbs draft decision leaked this week.
Abortions are generally less accessible in Scotland, which is part of the United Kingdom, than in the U.S., however.
Abortions are not legal in Scotland after 24 weeks of pregnancy — the point at which, under the 1973 Roe v. Wade framework, U.S. states can just begin to outlaw the practice, although some states choose to allow abortions to proceed later in pregnancy.
To have an abortion in the U.K. prior to the 24-week mark, a woman must have two physicians certify that the procedure would cause her less harm mentally or physically than giving birth to her baby.
Along with the U.S. and the Netherlands, Canada is one of the only Western countries that allows women to seek elective abortions after 20 weeks of pregnancy.
Canadian officials have said American women who can’t obtain an abortion in their state, were Roe to be overturned, could access the procedure in Canada if they want.
Canadian Prime Minister Justin Trudeau took aim at the Supreme Court’s draft opinion in a tweet, saying the choice to have an abortion is “a woman’s right and a woman’s right alone.”
Abortions are permitted liberally in Vietnam, where women do not need a specific reason to obtain the procedure well into their pregnancies.
Vietnam’s abortion rate is one of the highest in the world, a factor the Guttmacher Institute, which tracks reproductive policy, suggests is due in part to a strong cultural preference among Vietnamese women for having boys.
An analysis found that women in Vietnam were 2.9 times more likely to have had multiple abortions if they already had at least two daughters.