A High Court judge has called for international regulation of the "surrogacy market".
Mr Justice Moylan, a family law specialist, pointed to difficulties arising out of varying degrees of domestic regulation.
He said there was a "compelling need" for a "uniform system".
The judge, who sits in the Family Division of the High Court, has made his comments in a written ruling on a case involving a boy born four years ago in the Republic of Georgia following a commercial surrogacy arrangement involving a clinic in Georgia.
"This case provides a clear example of the difficulties created as a result of surrogacy arrangements being subject to varying degrees of domestic regulation, from significant regulation to none at all, and also because of the existence of significant differences in the effect of such domestic regulation," he said, following a hearing in Leeds.
"There is, in my view, a compelling need for a uniform system of regulation to be created by an international instrument in order to make available an appropriate structure in respect of what can only be described as the surrogacy market."
No one involved in the case was named.