Principle 4: Special protection measures in returning child victims International law requires that child victims of trafficking be accorded special measures of protection and assistance. The majority of OSCE participating States have not established standard procedures for determining the best interests of child victims with regard to status, residency, care arrangements or the determination of durable solutions. Practice shows that a commitment to the principle of the best interests of the child, even if enshrined in law, is not sufficient to guarantee the effective implementation of that principle. Even when such procedures are in place, they are not always followed.198 In terms of the protection and assistance measures that are in place in the OSCE area, some OSCE participating States have introduced legal provisions for the appointment of a temporary legal guardian for unaccompanied child victims of trafficking.199 The number of unaccompanied minors returned from or to OSCE participating States is low. Such returns are usually voluntary and undertaken via programs implemented by international organizations such as the IOM.200 There are reports that unaccompanied and sometimes undocumented children are being returned to country borders, without prior assessment of their best interests and outside the terms of the EU readmission agreement.201 Recorded cases of return by IOM indicate that, prior to return, assessments are routinely conducted to determine the best interests of the child.202 In the EU, according to a recent study, most member states do not forcibly return unaccompanied children but do return children as part of a family unit, and in some cases return children under voluntary return programmes.203 198  E-notes Report, p. 90; European Union: European Agency for Fundamental Rights, Child Trafficking in the European Union: Challenges, Perspectives and Good Practices, 7 July 2009, p. 95. 199  E-notes Report, p. 90. 200  European Migration Network (EMN), Policies on Reception, Return and Integration arrangements for, and numbers of, Unaccompanied Minors – an EU comparative study, May 2010, pp. 71-75. 201  UN Office of the High Commissioner for Human Rights (OHCHR), UN Special Rapporteur on the Human Rights of Migrants, Statement on Mission to Albania, December 2011. 202  European Migration Network, Policies on Reception, Return and Integration, op. cit., note 200, pp. 116 and  119. 203  European Council on Refugees and Exiles, Comparative Study on Practices in the Field of Return of Minors : a Checklist to Achieve Good Practices When Considering the Return of Children to Third Countries: A Tool for Quality Planning for Member States, December 2011, HOME/2009/RFXX/PR/1002, p. 12. Guiding Principles on Human Rights in the Return of Trafficked Persons 67