ln Japan the organ transplantation act was enacted ln October 1997. Once again , questlons were raised which were lntensely discussed during lts consideration . One question concerns the requlslte for organ remQva 【from the donor , name 【 y who has the rlght to permit it , the donor himself , his famlly or the soc 「 ety . ln this paper, the compar 「 sQn between Japanese act and the uniform act of the USA , the transplantatlon act ln France and Germany will be made regarding the three partles.

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... I these three acts , American , French and . German , commonly declare the first principle to be the right to self decision maklng of the person concerned . They albw removal when the person expressed hls agreement e 「 ther 「 n writing or orally and forbid「 t when he expressed his refusal . In the case his wil ]ls unknown , his famlly may make decislon for hlm in the USA and Germany . On the contrary , in France, removal is a110wed w 「 thout the w 「 隆 of the family . For the soc 「 ety supports the transplantation , it may suppose that its member shares the same will tacitly . In the case of the removal from the Mng donor , not only in FranGe but also in Germany , the will of the soGlety overrules the individual will in order to protect h「 s body 、 The removal from Ilving minor ls f6rbidden . As in the USA , France and Germany , the Japanese act also respects the autonomy of the person concerned . However , in the case of bra「 n death, the veto Qf his family ls respected even when he himself expressed his agreement . it might be necessary to have a consistency concerning the prlority of the self decision making , at Ieast in the text Qf the act, Japan still has no act regulat 「 ng the Iiving donatbn in general . The declarat「 on of the protect「 on of the body by the soclal wil 目 s required .