I thought it might be useful to make a simple chart to demonstrate why it’s meaningless to claim that one country has more trafficking than another, based on their official statistics. Seeing as this comes up all the time.
You can click on it to enlarge:
There are a few explanations and disclaimers I need to get in:
- The chart is based on my own interpretation of each country’s laws. There is undoubtedly scope for disagreement in some of the details – but not, I believe, on the overall picture.
- The big centre column refers to adult trafficking only. I included an age qualifier for Germany because its law treats 18 to 21 year old adults as children.
- For “Elements of Trafficking”, I’ve used the three-part schema derived from Article 3(a) of the UN Trafficking Protocol. The headers are a common shorthand and are not to be interpreted literally (“control” doesn’t only mean actual control but can include deception, for example).
- Even within a single element, definitions can vary widely; eg, in the UK the “movement” element strictly requires travel, while the Irish definition adheres more closely to the broader Protocol criteria.
- Finally and most importantly, the chart reflects what the law actually says – not necessarily how it’s interpreted in practice. It’s theoretically possible that the reporting bodies in each country actually apply a more uniform definition in the process of collecting statistics. But that’s for the people who put faith in the official stats to demonstrate – and to my knowledge, not one of them has done so.
All that said, I think this chart makes one thing crystal clear: when countries tally up their “trafficking” figures, they aren’t necessarily counting the same thing. And unless these distinctions are controlled for in comparative studies, which they haven’t been so far, the evidential value of those studies is pretty close to nil.
Sweden – Chapter 4 § 1 a of the Penal Code (2010:371) as translated in this Swedish police report
Netherlands – Article 273f of the Criminal Code