[fulafel]

(Note: I made no claims, just jumped in to provide references about the state of affairs in some European countries)

The pages I gave are specific case studies of the law in Germany & France. You are right that there is not too much overarching EU level legislation about these things, it's generally in national legislation and up to each country.

[sambe]

Sorry, I should have referred to the grandparent's claim (which is also not backed by the case studies, good examples though they are).