

Image credit: Greg Moss / Wellcome Sanger Institute
The use of embryonic and foetal material in research is an emotive topic. We break this topic down by taking a closer look at the promise of this work, the regulatory requirements necessary to conduct it, and how the Wellcome Sanger Institute is upholding these standards.
The use of human embryonic material in scientific research has opened new avenues for understanding the fundamental processes of human development, as well as the origins of disease and potential avenues for treatment. By studying these early stages of development, researchers can uncover mechanisms that are otherwise inaccessible, providing insights that are crucial for advancing human health. Nonetheless, this research also raises questions about the boundaries of scientific exploration and the responsibilities of researchers around the world.
As research continues to evolve, scientists are focussed on ensuring work with embryonic and foetal material is conducted within ethically sound and transparent frameworks. This blog explores the opportunities and challenges of using embryonic and foetal material in research, the regulations that have set standards for ethical use and how the Wellcome Sanger Institute is keeping at the forefront of this work and driving innovation whilst upholding these standards. It also touches upon associated work and where this field is heading in the future as the field increasingly integrates in silico models alongside experimental approaches.
The key regulations for the use of sensitive materials
Scientists use the term embryo to describe human development from fertilisation through the first eight weeks.1 Beyond this stage, it is usually referred to as a foetus.1 By studying embryos, we can uncover more about the early stages of human development when most of the cell types in the body are specified and organised. These processes are highly dynamic and occur in ways that cannot be fully replicated in other models. Understanding them is crucial for revealing fundamental biological mechanisms that underpin human fertility, congenital disorders and tissue regeneration. Insights gained at this stage can also provide foundations for developing therapies and interpreting how early developmental errors can lead to disease later in life.
In the UK, research using gametes – sperm and eggs – and live embryos up to 14 days of development is regulated by the Human Fertilisation and Embryology Authority (HFEA). This regulation is set out in the HFE Act 1990, which was amended in 2008. During this period, researchers can culture live embryos to discern what is going on during early development. While we do not conduct this type of research at the Institute, these studies provide crucial insights into fundamental developmental processes. The samples used are donated with informed consent in cases where an individual has had successful rounds of in vitro fertilisation (IVF) and more embryos have been created than needed, or the IVF embryo is not suitable for implantation. Other types of HFEA-licensed activities include creating human embryos in vitro, storage and use of human reproductive cells for human application, such as for IVF, and deriving stem cells from reproductive cells or embryos. When an embryo regulated under the HFEA is formalin fixed paraffin embedded (FFPE), the tissue becomes preserved for study. Although the embryo is no longer living, researchers can still extract genetic information for research. Once fixed, these samples are no longer regulated by the HFEA.
The period between weeks two to four of development is sometimes referred to by scientists as the ‘black box’ window.2 To date, regulation requirements have made it difficult to understand more about what happens during this period. Last year, the Progress Educational Trust (PET) – a small charity that educates and debates the responsible application of reproductive and genomic science – held their 2024 annual conference which some of our researchers at the Institute attended. At this meeting, HFEA announced the recommendation that the law should be changed to extend the day 14 limit on in vitro human embryo research to day 28.3 Research after day 14 would enable scientists to understand more about the ‘black box’ window, providing potential insights into congenital diseases and complications during early pregnancy. HFEA has made it clear that this would only be approved on a case-by-case basis and after extensive public engagement. Such an amendment would require a change to the law and therefore, has to be discussed by the UK Government.
As HFEA-regulated samples at present cannot be cultured in vitro beyond day 14, researchers seeking to examine material from later stages of early pregnancy cannot currently rely on these samples. Instead, such work is regulated by the Human Tissue Authority (HTA), which enforces the Human Tissue Act 2004 (HT Act). The HTA regulates activities concerning the removal, storage, use and disposal of human tissue including pregnancy remains such as embryonic and foetal tissue.
Samples from pregnancy remains can come following pregnancy loss or elective termination. These samples are classified as the mother’s tissue under the HT Act. Samples can include biopsies, tissues or FFPE material.
Ensuring ethical use of sensitive materials at Sanger
At the Sanger Institute, we do not hold HFEA or HTA licences as our work does not involve procedures, such as creating material, that require these licences. Instead, we receive non-living in vitro embryos such as FFPE samples as well as tissues, cells or extracted nucleic acids from pregnancy remains all under Research Ethics Committee (REC) approval. RECs carefully review research applications and only projects that receive a favourable opinion are permitted to proceed.
When wanting to obtain such samples from external sources with the relevant licences, researchers at the Institute work closely with colleagues in the Legal and Research Governance (LeGo) teams. The Legal team will review contractual obligations, and the Research Governance team support ethical and compliance considerations. Researchers at the Institute must complete a Human Materials Form Electronic (HuMFre), an internal ethical due diligence form reviewed and approved by the Research Governance team. The form captures key details such as sample responsibility, donor consent conditions, data sharing, ethical approvals, project use, handling of remaining samples and approval end dates. Samples cannot be received or used onsite until a contract, ethical approval and an approved HuMFre are in place.
Receiving samples through informed consent
We are very privileged to have access to the Human Developmental Biology Resource (HDBR), a human embryonic and foetal biobank which provide samples to researchers internationally. Most of the foetal tissue used in research at Sanger from elective terminations of pregnancy comes via the HDBR, which is donated from collaborating clinics in the UK. Only after an individual has decided to have a termination will they be approached about donating material to avoid influencing the choice of the individual. After they have been counselled about the termination of their pregnancy, potential HDBR donors are invited to give explicit written consent for the foetal material to be collected and used in research. HDBR holds an HTA licence and ensures that all projects are assessed for ethical and scientific merit. Once approved, all materials transferred to Sanger are then covered by a material transfer agreement – a legal contract governing the exchange of materials between organisations.
The Sanger Institute also receives materials that have been consented for use in specific research studies through collaborations with researchers from different organisations. For example, we collaborate on a research study to investigate factors supporting in vitro human embryo implantation and development in which we receive FFPE IVF embryos from the Babraham Institute in Cambridge. This ethically-approved research study receives material from individuals who have consented for their frozen embryos, remaining after their fertility treatment, to be donated for this particular study.
The storage and use of non-living, HFEA-derived material in research, such as the in vitro FFPE samples in this study, fall between the requirements of the HFE Act and the HT Act highlighting a gap between the two legislations. As mentioned, once an embryo is FFPE, it is no longer considered living and does not come under HFEA as it does not meet their legal definition of an embryo. However, it also does not come under HTA, as it is created outside of the body and therefore, does not count as ‘relevant material’. In order to address this gap, the Sanger Institute has extended policy requirements. If researchers are wanting to receive and use these types of samples, the Research Governance team will undertake an ethical assessment to ensure that the donors have been appropriately informed and consented for the use of these samples in research at Sanger.
“When it comes to sensitive materials, people understand that these have come from individuals at potentially one of the worst times in their life. If somebody is donating their material, that is a huge gift, and it is an honour for the researchers to be receiving those samples. So, they want to honour that gift and honour the donors and respect their wishes. I really do believe that researchers have that at the heart of their work.”
Dr Joanne Doleman,
Head of Research Governance for Trusted Human Research, Wellcome Sanger Institute
Using embryonic and foetal materials to delve deeper into development
One of the core aims of the Cellular Genomics programme at Sanger is to understand how human tissues develop in vivo, in order to reveal what goes wrong in disease and to inform the development of new diagnostics and treatments. The team aim to create models that mimic human biology and use them to test the effects of altering specific processes. However, to fully understand these processes, researchers need to draw on data derived directly from human tissues. The team specifically use these tissues to improve in vitro models – a cycle of refinement ensures their models recapitulate the complexity of human tissue architecture and can be easily scaled.
Model organisms such as mice, rabbits, pigs and even primates have long played an important role in research and continue to provide valuable insights. At the same time, some of their developmental mechanisms differ from those of humans at the molecular and cellular level. This means that the insights scientists obtain do not fully translate into humans. For example, unlike humans, mice lack the same degree of growth and folding of the outer layer of the brain, which limits how much we can learn about the origins of human brain complexity from studying mice alone. It is clear that to develop treatments for humans, we still need to use human biological resources.
At the Sanger Institute, Head of Cellular Genomics, Professor Muzz Haniffa and her team recently created a prenatal skin atlas – a comprehensive reference map describing how the skin develops before birth. Here, they sampled prenatal skin across different time points during the first and second trimesters of human development. The samples were provided by HDBR and the Cambridge BioResource. The data generated were further used for benchmarking a pluripotent stem cell (PSC) derived skin organoid model – a 3D, self-assembled cell culture system that mimics the structure and function of human skin in vitro.4,5 This was to understand what the similarities and differences were in order to improve the model. They found that almost all major cell types in the skin were recapitulated in the skin organoids, aside from immune cells. Now, there are multiple efforts within the team to build on this work by leveraging the existing skin organoid model and further enhancing it with specific immune cells, such as patient-derived macrophages, which they found to have a key role in skin development.
With any human tissue sample, researchers can only get a snapshot of what is happening within that tissue at that time point. To overcome this, Feri Torabi, PhD Student in Muzz Haniffa’s group, is using the in vitro PSC-derived skin organoid to label progenitor cells – biological cells that can differentiate into specific cell types – with unique genetic tags. This approach allows her to track the cells over time and map how mature cells relate to other cell types within the context of 3D skin tissue. Once we have this powerful platform, the team envisions using it to model diseases andexplore the effects of drugs across different skin conditions.

Development of skin organoid containing barcoded green cells for lineage tracing applications. Image credit: Haniffa Lab / Wellcome Sanger Institute.
Dr Freddy Wong, Staff Scientist in Dr Roser Vento-Tormo’s group, is also adopting a similar approach but for modelling the human endometrium – the lining of the uterus. Freddy and colleagues have expanded our understanding of the molecular and cellular composition of the endometrium from a range of tissue samples from patients and embryonic sources. The team aims to use these insights to mimic the in vivo state in an in vitro model.

Endometrial epithelial organoids transduced with and sorted for the constitutive expression of barcoded fluorescent proteins to track the clonal lineages in the organoids. Image credit: Freddy Wong / Wellcome Sanger Institute.
There are a lot of diseases that are the result of dysregulated endometrial cells, including endometriosis that affects roughly 10 per cent of women worldwide.6 Creating models of healthy and diseased states will allow the team to disrupt and understand how regulatory mechanisms are altered during disease progression.
Both of these approaches demonstrate the use of prenatal tissue to generate atlases that will act as ‘recipe books’ for researchers to then create in vitro models. Once we have these models, scientists can then fine tune them to better mimic in vivo tissues, bringing us even closer to replicating real human biology.
The future of embryonic and foetal materials in research
Stem cell-based embryo models are 3D structures that mimic aspects of early human embryo development. While we do not currently work on these models at the Institute, they have become a major topic of discussion in recent years. They are created from PSCs and express some of the same genes as humans during in vivo development. Although these models are not the same as human embryos, there are some ethical considerations due to the similar aspects of early human development. There has also been a lot of discussion as to what regulations these models fall under. Current scientific understanding indicates that these models are not equivalent to embryos, as they do not fully replicate in vivo development and are not thought to have the capacity to form a human being. As a result, in 2025, the International Society for Stem Cell Research (ISSCR) updated their guidelines to refine how these models should be governed. In the future, as these models continue to develop and become more similar to embryos in vivo, there needs to be discussion and awareness across the field that a new set of regulations and/or legislation may be required to govern and regulate this work.
“A key thing we as scientists fail to communicate clearly to the public is that the current success rate of these stem cell-based embryo models is so small. For example, out of 100, maybe three will work. It is not that reproducible yet. As a community, we have a lot of work to do to then get it to a scale that is reproducible enough that we can use it for further studies.”
Feri Torabi,
PhD Student, Cellular Genomics programme, Wellcome Sanger Institute
Another key area of development is the use of artificial intelligence (AI) to integrate the wealth of scientific knowledge obtained from these models. There are now numerous human embryo and foetal atlases, covering different time points and organs. To uncover the general principles of how development works, we need to combine data from these studies, and AI is ideally suited to this. The use of embryonic and foetal material in research provides the foundation to establish models that recapitulate in vivo, allowing us to have a clearer understanding of various systems in the body. In turn, this will enable us to generate fully in silico models of cells down the line, making predictions without having to do laboratory experiments. In the future, it is expected that as foundational knowledge grows, the reliance on embryonic and foetal samples may decrease.
In addition, one of the big advantages of both in silico and in vitro models is that researchers can attempt to perform gene editing at scale using advanced tools such as CRISPR-Cas9. This would help them validate findings in a complete tissue model setting, rather than each cell in isolation. This will then allow researchers to better understand the key factors that can lead to pregnancy loss or developmental origins of disease.
A key aspect of all of this work will be transparency and effective communication with the public. Setting clear expectations on what the potentials are, the challenges and most importantly, the regulations in place to prevent misuse is essential. The use of embryonic and foetal material in research will inevitably remain a controversial and emotive topic, particularly as it is intertwined by religious and political beliefs. For certain individuals and groups, the use of any embryonic or foetal material may be strictly forbidden, and many countries have legislations that are far less permissive than the UK. Nonetheless, enabling an open dialogue between scientists, policymakers and the public will be critical to build trust and ensure that all research is conducted with a legal and ethical framework at the forefront.
References
- Venkatesh A, Iltis AS, Matthews KR. Transparency in controversial research: A review of human embryo research publication ethical disclosure statements. Stem Cell Reports 2024; 19: 28–36. DOI: 10.1016/j.stemcr.2023.11.006.
- Appleby JB, Bredenoord AL. Should the 14‐day rule for embryo research become the 28‐day rule?. EMBO Molecular Medicine 2018; 10: e9437. DOI: 10.15252/emmm.201809437.
- Progress Educational Trust (PET). UK regulator recommends extending human embryo research limit to 28 days. December 2024 [Last accessed: October 2025].
- Lee J, et al. Hair-bearing human skin generated entirely from pluripotent stem cells. Nature 2020; 582: 399–404. DOI: 10.1038/s41586-020-2352-3.
- Lee J, et al. Generation and characterization of hair-bearing skin organoids from human pluripotent stem cells. Nature protocols 2022; 17: 1266–1305. DOI: 10.1038/s41596-022-00681-y.
- Endometriosis UK. Endometriosis Facts and Figures [Last accessed: October 2025].





