In Korea, most baby boxes are operated by private institutions rather than the government. It is at this point that many perspectives towards the baby boxes differ. One side claiming that baby boxes protect the human rights of children and parents, and the other that it promotes infant abandonment, are in conflict. In addition to these problems, it has been suggested that a realistic solution, not just the baby box, is needed in consideration of single parents. Let's find out how other countries deal with the issue of abandonment of infants as well as the baby box.

            In the United States, there is a “Safe Haven Law” for the safety and welfare of abandoned children. According to the “Safe Haven Law”, if parents bring the child to a safe designated place, they will not be punished for abandonment, even if the child is abandoned. The law, which began in Texas, is now implemented in all 50 states. There are three things to consider to be granted immunity under this law. First, the child must be placed in a safe place from 72 hours to 30 days after birth. Safe places are fire departments, designated hospitals, and police stations. Second, there must be no wounds on the child caused by abuse. Most states don’t punish parents who give up their child in a safe, unharmed condition. However, if there is evidence of child abuse, the anonymity and disclaimer (immunity) of the parents are forfeited. Third, the anonymity of the mother must be guaranteed. The law must guarantee the anonymity of the child’s mother, and prohibits forcing parents or their guardians to provide information about the mother. According to the “National Safe Haven Alliance” website, more than 4,500 children (as of August 2022) have been saved through the “Safe Haven Law.” However there are some concerns that this law focuses only on leaving the child in “a safe haven” and allowing the child to be adopted. It also does not protect the child's interests based on Convention on the Rights of the Child (CRC).

      France institutionally bans baby boxes, but has a system called as “l’accouchement secret” that officially provides anonymous birthing. According to Article 326 of the French Civil Code, a pregnant woman can ask the government-approved medical institution to keep her identity secret. In this case, the medical institution cannot ask the mother for any documents regarding her identity or marital status. It also does not require the mother’s parental consent if the birth mother is not yet of legal age. If the mother wants to relinquish custody, she has to go through several procedures with the child protection service representative immediately after childbirth. The documents generated at this time are confidential and are kept in the Conseil National D'accès Aux Origines Personnelles (CNAOP), French national institution. Regarding this law, The Coordination des actions pour le droit à la connaissance des origines (CADCO), organizations working for birth information, assessed that French law caused serious inequity to babies deprived of information about their origins. On the other hand, organizations that work for the human rights of families, like “the L'Union nationale des associations familiales (UNAF)” and “Le Syndicat national des gynécologues et obstétriciens de France”, “la Famille adoptive française”, took the opposite side, stating that the rights of both the mother and the child will not be protected if they are forced to reveal the identity of mother at birth.

        Germany's baby box system is not a public institution nor is it a private institution with a legal basis like Korea. However, Germany enacted the system called as “vetrauliche Geburt” in 2013. Under this law, the child’s mother can receive counseling on child support, open adoption, and anonymous childbirth at a pregnancy counseling center. At this counseling center, the mother's personal information is recorded, the documents are sealed in an envelope, and the mother's pseudonym, place and date of birth, and information about the medical institution are recorded on the surface of the envelope. Medical institutions report births to public officials based on this document. A child born through this law can access their mother's information through legal procedures after the age of 16. If the mother does not allow this, they cannot access information. In 2017, a report by human rights protection association called as “Bundesministerium fuer Familie, Senioren, Frauen und Jugend” evaluated that the “vetrauliche Geburt” was effective in helping pregnant women. It also reported that the “vetrauliche Geburt” has reduced the number of anonymous births that existed before. However, the number of abandoned and killed newborns was relatively unchanged compared to before “vetrauliche Geburt”’s implementation.

These countries are guaranteeing the right to anonymously give up parenting. The United States grants immunity to parents for abandonment of infants through the “Safe Haven Law”, and France allows parents to have children anonymously through the “l’accouchement secret”. Germany has also enacted the “vertrauliche Geburt”, which allows mothers to keep their information anonymous. Based on these cases, Korea should consider how to solve the baby box controversy as well as the problem of abandoning infants.

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