In Europe as in the U.S. different states have different laws about same sex marriages, and some states don't recognize the same sex marriages performed in other states:
On Gay Marriage, Europe Strains to Square 27 Interests
"The European Commission, the guardian of European Union treaties, has been working on ways to make life easier for people who move across borders.
"But although for two years it has been studying ways to facilitate the free circulation of civil status documents, including birth, death and marriage certificates, the proposal is still awaiting action. And when it goes forward later this year, the plan may not cover marriage. “For now, I think it is important to take one step at a time,” Viviane Reding, the European justice commissioner, said in an e-mailed response to questions.
"Opponents of gay marriage argue that any attempt in Brussels to require countries to recognize same-sex marriage certificates issued in another member state would, in effect, require them to introduce gay marriage whether they wanted to or not.
“A general application of the rule of mutual recognition of civil status documents will result in a situation where the political and social choices of some member states would be imposed on all the others,” CARE for Europe, a Christian lobby group, argued in its submission to the commission, echoing numerous opponents.
"So for now, gay couples and families are fighting their own battles — often at considerable expense."
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