A quote from Teresa Küchler at EUobserver, 16 November 2006

EU member states are lining up to attack a European Commission proposal to establish common rules for cross-border divorces […]. The proposal – called Rome III and presented last July – sets out which national legislation should apply in the case of a couple of two nationalities or a couple living in their non-native country […]. Rome III would impose the law of the country where they live or have the strongest ties to. […] [A] Swedish justice ministry document [describes] a potential scenario in which […] a Swedish woman who marries an Iranian man in Sweden and emigrates to Iran but after several years decides to leave both her spouse and his country and go home. “The proposal means that Iranian divorce law would be applied by the Swedish court,” the justice ministry study states.

[…] Malta has stated it will oppose any proposal that would oblige Maltese courts to apply foreign laws to circumvent its ban on divorce. “If Ireland were to adopt and implement this measure, this would allow EU nationals resident in Ireland to obtain a divorce in our courts on substantially different and less onerous grounds than that provided for in our constitution”, the Irish justice ministry recently said, planning an opt-out from Rome III. […] “It would sadly not bring about the benefits it was intended to bring about, at least not in the UK,” a UK diplomat said, confirming that the UK has also requested an opt-out from the bill.