ΑΛΛΗΛΕΓΓΥΗ ΣΤΗΝ ΕΕ: ΕΞΕΛΙΞΕΙΣ ΣΤΟ ΠΕΔΙΟ ΤΗΣ ΠΡΟΣΦΥΓΙΚΗΣ ΠΡΟΣΤΑΣΙΑΣ ΚΑΙ ΠΡΟΚΛΗΣΕΙΣ ΣΤΗΝ ΕΕ ΚΑΙ ΣΤΗΝ ΕΛΛΑΔΑ

214 Unaccompanied minors and the dangers from the administrative practice the best interest of the child, fundamental procedural safeguards, principles and provisions of the national 3 , international 4 and european law. 5 The areas where most of the systemic deficiencies and problems of the adminis- trative practice are recorded, are the following: I. Reception and Identification The majority of the unaccompanied minors who arrive in Greece lack the nec- essary documents certifying their childhood. As a result, the registration of their personal data, and especially their age, is based on the one hand on their mere oral declaration and on the other hand on the visual and scientifically unsubstanti- ated estimation of the European Border and Coast Guard (Frontex) staff, which assists the Greek authorities in registration process. However, the declarations of children, especially of those between the age of 15 and 18 and those who seem to be older than their actual ages, are treated with great distrust by the authorities. Such practice has the below mentioned consequences: (a) the official documents register a different date of birth so as to appear as adults. In practice, such reg- istration is rarely changed at a later stage and only under the condition that they have legal representatives, (b) they are treated as adults, (c) they automatically lack the procedural guarantees that a minor should enjoy and (d) the decisions of the relevant Director of the Reception and Identification Center, adopt the data as recorded by the Frontex staff. Unaccompanied minors may theoretically appeal against these decisions, since the time limit is extremely short (10 days), they are closed to the Reception and Identifications centers, they do not have evidence and particularly they are deprived of a guardian and legal assistance. Besides, the national capacity for accommodating unaccompanied and separated children (UASC) is still far from meeting the required needs. According to the Na- tional Centre of Social Solidarity (EKKA), as of 31 December 2017, the estimated number of unaccompanied minors currently in Greece is 3.350, the total number of places available for minors is 1.101, while a number of the unaccompanied chil- dren who are on the waiting list for shelter is of 2.290. Out of those, 438 unaccom- 3. Article 21, Constitution of Greece, available at: http://www.hri.org/docs/syntagma/ artcl25.html#A3 . 4. Specific safeguards and guarantees for the protection and care of children are contained as State obligations in international treaties. The UN Convention on the Rights of the Child (‘CRC’) [especially Articles 3 and 22], the International Covenant on Civil and Political Rights (‘ICCPR’) and the International Covenant on Economic, Social and Cultural Rights (‘ICESCR’), all acknowledge the specific vulnerability and status of a child and the extreme vulnerability of unaccompanied children. 5. Article 24, Charter of the Fundamental rights of the European Union, available at: http://www.europarl.europa.eu/charter/pdf/text_en.pdf .