A/HRC/17/36 Child and under the 1995 Additional Protocol to the European Social Charter. He also recalled that the inclusion of a collective communications procedure had been discussed but rejected during the negotiations on the Optional Protocols to the Convention on the Elimination of All Forms of Discrimination against Women and to the International Covenant on Economic, Social and Cultural Rights. 48. Numerous delegations declared that they were not in favour of including a provision in the optional protocol that would extend the competence of the Committee to the examination of collective communications. They said, inter alia, that such a provision was without precedent, represented no added value as no protection gap existed, that it overlapped with the inquiry procedure for grave or systematic violations and, to a large extent, with the reporting procedure, and that the provision on individual communications already envisaged the submission of communications by groups of individuals. Both the individual communication and the inquiry procedure could ultimately lead to the amendment of laws and policies. They saw more merit in keeping the inquiry procedure, which existed also in other instruments. Collective communications also posed difficulties in terms of exhaustion of domestic remedies, as victims could not be easily identified. They would result in abstract proceedings, undermine the right to response of States and, ultimately, the integrity of the communications procedure. Some argued that having to deal with collective communications would overstretch the Committee’s limited time and resources. Questions were asked as to what should be understood by “grave and systematic”. These delegations similarly highlighted the need to ensure broad adhesion to the draft optional protocol, which would not be favoured with the inclusion of a provision allowing collective communications. A problem exposed by many States was also the lack of clarity with regard to the fulfilment of the requirement of exhaustion of domestic remedies for collective complaints. 49. A number of delegations, experts, including members of the Committee on the Rights of the Child, national human rights institutions, UNICEF and non-governmental organizations, were in favour of such a provision, as they felt that it filled a gap in the protection mechanisms. They considered that collective communications could play a preventive role; prevent the Committee from having to examine identical individual communications separately and therefore reduce the caseload; eliminate the difficulty of identifying individual victims ready to submit their cases, and the re-victimization of the children authors of such communications; would be particularly appropriate in connection with children belonging to vulnerable groups, such as children in institutional settings, child victims of prostitution or child victims of traditional practices as it would, inter alia, reduce the risk of reprisals. They said that there was no overlap between the collective communications and the inquiry procedure, and stressed the positive impact they could have on the interpretation of the Convention by the Committee. These delegations proposed, inter alia, that the possibility of submitting collective communications should not be limited to non-governmental organizations with consultative status with the Economic and Social Council, but be open to non-governmental organizations constituted under the national legal systems. National human rights institutions welcomed the possibility for them to submit collective communications and suggested including a reference to the Paris Principles. Such a reference was considered too limitative by some delegations. It was suggested that collective communications should not be limited to cases of “grave or systematic violations” but to “recurring violations” or “violations of rights of multiple victims”. Some suggested that the provision on collective communications should include an opt-in or an opt-out clause. 50. Some delegations supported the proposal presented by the Chairperson-Rapporteur allowing States to accept collective communications by opting in at the time of signature or ratification of or accession to the protocol and lowering the threshold to “recurring violations affecting multiple individuals”. Others preferred an opt-out clause or at least 13