Allocation systems for organ transplantation ideally ensure that the right organ is offered to the right patient at the right time, optimizing graft utilization and minimizing waiting list mortality. Nevertheless, the allocation of livers from donors after circulatory death (DCD) introduces a complex array of challenges that can supersede these goals. These challenges include concerns regarding organ quality, logistical hurdles, variations in center practices, and the prevailing legal environment, all of which have significantly shaped the realities of DCD liver allocation. The historical context, current practices, and future directions of DCD liver allocation in North America and Europe reveal a landscape that is continuously evolving. This chapter aims to provide a review of these developments, highlighting how allocation policies have been shaped by changing donor and patient characteristics, advances in medical technology, and ethical considerations.