VERA EGENBERGER, ENAR - European Network against Racism, Brussels

- Recommended strongly using the term ‘undocumented’ or ‘irregular migrants’ instead of ‘illegal’ in order to avoid stigmatisation.

- Recommended exactly and appropriately formulating the principle of giving priority to voluntary return in all relevant documents concerning return policy.

- Suggested adding to the "Groups that require special protection" minors, pregnant women and persons who are seriously ill (these groups should not only be particularly protected against expulsion but should on no account be detained).

- With reference to the section "Binding standards of detention" (item 3.1.3.) of the Green Paper proposed the inclusion of:

- the right of the detained person to be immediately informed, in a language he/she fully understands, of the reasons for expulsion and detention,

– the right to contact diplomatic authorities and human rights protection bodies or NGO,

– protection of family union and the rights of the child,

– time limit for detention not exceed 15 days.

- With regard to the actual removal, suggested in particular that training for staff carrying out return enforcement should include training on human rights and anti-discrimination.