A/HRC/6/8 page 10 50. Switzerland noted the need to clarify whether an opt-out provision in article 2 would apply to article 3. Germany stated that article 3 should provide for an opt-out possibility with regards to paragraph 1. Belgium, China, Finland, the United Kingdom and Venezuela (Bolivarian Republic of) said that it was unclear whether the admissibility criteria in article 4 also applied to collective communications. India stated that article 3 was incompatible with article 4. 51. Belgium, Mexico, Norway and Spain underscored the importance of allowing NGOs to lodge communications on behalf of victims. India, Guatemala, Norway, Venezuela (Bolivarian Republic of) and the United States mentioned that NGOs already have standing under article 2 when assisting those with a sufficient victim nexus, while Spain stated that article 2 does not necessarily cover this dimension. Finland favoured having NGOs draw attention to shortcomings in the implementation of the Covenant. Austria, Egypt (on behalf of the African Group) and Ethiopia stressed the importance for groups of individuals to be able to submit communications. This possibility was included in article 2. 52. The Republic of Korea expressed concern that article 3 could lead to unreasonable interference with national policies. 53. Norway, Russia and the United Kingdom stated that the Committee already had the competence to assess “unsatisfactory application or implementation of the Covenant” under the reporting procedure. Austria, China, Greece and the Republic of Korea raised concern that article 3 might give rise to an unprecedented number of communications. 54. Belgium, Brazil, Ecuador, Ethiopia, Mexico and the NGO Coalition expressed concern about the limitations on standing of NGOs and about using ECOSOC status as a criterion for standing. Belgium, Brazil and Burkina Faso suggested adding national NGOs to a new paragraph 3 of article 2. Ethiopia proposed that paragraph 2 should allow any organization with knowledge of a violation to represent a victim. Ecuador suggested following the approach of the American Convention on Human Rights to grant standing to legally recognized non-governmental entities. 55. Portugal stressed that certain rights under the Covenant can only be exercised collectively, notably article 8, paragraph 1, subparagraphs (b) and (c). Before taking a decision on whether to maintain article 3 or not, this particular feature of the Covenant had to be borne in mind. 56. The FIDH and the ICJ expressed support for a collective communication mechanism under an optional protocol. Article 4 57. On paragraph 1, Argentina, Belgium, Mexico, Slovenia and Switzerland agreed with the text as drafted. 58. China and Turkey cautioned against allowing the Committee to determine whether the application of domestic remedies has been unreasonably prolonged. Venezuela (Bolivarian Republic of) suggested that the Committee could interpret this on a case-by-case basis.