Cross-cultural issues in European bioethics.

European biomedical ethics is often contrasted to American autonomy-based approaches, and both are usually distinguished as 'Western'. But at least three 'different voices' within European bioethics can be identified: the deontological codes of southern Europe (and Ireland), in which the patient has a positive duty to maximise his or her own health and to follow the doctor's instructions, whilst the physician is constrained more by professional norms than by patient rights; the liberal, rights-based models of Western Europe, in which the patient retains the negative right to override medical opinion, even if his or her mental capacity is in doubt; the social welfarist models of the Nordic countries, which concentrate on positive rights and entitlements to universal healthcare provision and entrust dispute resolution to non-elected administrative officials.