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The term "civil law" as applied to a legal tradition actually originates in English-speaking countries, where it was used to lump all non-English legal traditions together and contrast them to the English common law. However, since continental European traditions are by no means uniform, scholars of comparative law and economists promoting the legal origins theory usually subdivide civil law into four distinct groups:

• French civil law: in France, the Benelux countries, The Canadian Province of Quebec, Italy, Spain and former colonies of those countries;
• German civil law: in Germany, Austria, Switzerland, Greece, Portugal, Turkey, Japan, South Korea and the Republic of China;
• Scandinavian civil law: in Denmark, Norway and Sweden. Finland and Iceland inherited the system from their neighbours and colonial masters.
• Chinese law is a mixture of civil law and socialist law.

Portugal, Brazil and Italy have evolved from French to German influence, as their 19th century civil codes were close to the Napoleonic Code and their 20th century civil codes are much closer to the German Bürgerliches Gesetzbuch. Legal culture and law schools have also come near to the German system. The other law in these countries is often said to be of a hybrid nature.

The Dutch law or at least the Dutch civil code cannot be easily placed in one of the mentioned groups either, and it has itself influenced the modern private law of other countries. The present Russian civil code is in part a translation of the Dutch one ^{[citation needed]}.