FACTBOX: Organ donation regulations in some major countries

(Reuters) - The European Union's health chief has proposed an EU-wide organ donor card and criticized a Dutch reality TV show in which a dying woman will choose a recipient for her kidneys.

Here are some key facts about laws governing organ donation in some major countries:

* SINGAPORE: The city state's organ donor policy assumes all citizens are willing donors, unless they have registered with the government that they wish to opt out.

* EUROPEAN UNION: Many European countries, including Austria, Belgium, Denmark, France, Italy, Greece, Norway, Switzerland, Spain and Sweden have laws similar to Singapore's "presumed consent" legislation. In most of these countries, family consent is also sought.

-- Under the "informed consent" laws in Denmark, Germany, Ireland, the Netherlands and the United Kingdom, individuals must make a conscious decision to donate organs after death and indicate their willingness to do so.

-- Spain has the highest recorded donor rate in the world at 35.1 donors per million population.

-- Europe which has a list of nearly 40,000 patients waiting for an organ.

* UNITED STATES: Organ donation in the United States is based on the principle of informed consent.

While federal law lays down the policies, each state has its own Uniform Anatomical Gift Act which provides for a donor card, often part of the state's driver's licenses, permitting the removal of organs after death. The cards must be signed by a person over 18 years of age and witnessed by two other adults.

-- Most states have laws stating the consent of the potential donor is sufficient but enforcement is not uniform and families are still asked to consent.

-- More than 96,000 people are on the organ transplant waiting list.

-- U.S. and European laws ban the sale of human organs and most tissue for transplant is taken fresh from the bodies of the newly deceased. A smaller amount also comes from live donors, mostly people giving to save the life of a relative or friend.

* BRAZIL: Brazil passed a law in 1998 mandating presumed consent and making every citizen a potential donor after death but it triggered a public outcry. The Federal Attorney later conceded that families could prevent the removal of organs for transplant and presumed consent was abolished in 2000.

* JAPAN: Both the potential donor and the family must consent to establish "brain death" as well as organ transplantation. The donor card must be signed by the potential donor as well as two witnesses, including a close relative. The family has the right to withdraw consent to donate at any time.

Sources: Reuters; UK Parliament (www.parliament.uk); www.organdonor.gov; Global Observatory on Donation and Transplantation (www.transplant-observatory.org)