A/HRC/23/46 Dublin does not appear to be in line with such a principle. To the contrary, obliging the country which is the first point of entry to be responsible for processing most asylum claims is not sustainable for the countries at the external borders of the European Union, and this may contribute to the difficult access to the asylum system, as the Special Rapporteur observed in Greece. While noting that the recast Dublin regulation will lead to some improvements, including the establishment of an early warning mechanism, the Special Rapporteur points out that it does not remedy the underlying structural problems in the Dublin system. 72. Another overarching problem is the lack of institutionalized family reunification for irregular migrants, beneficiaries of subsidiary protection, asylum seekers, and, in particular, unaccompanied migrant children. While it is true that the Dublin Regulation provides that unaccompanied minors are to be sent to a member State where a parent or guardian is present, this is often not carried out in practice due to lack of capacity and coordination. Unaccompanied children, whatever their administrative status, should always be sent to countries where they have some family ties, when this is in their best interests. The Special Rapporteur hopes that the new Common European Asylum System (CEAS) will assist in remedying these issues. Acknowledging and addressing the “pull factors” 7. 73. Furthermore, the European Union must not shy away from addressing the pull factors for irregular migrants. In particular, the demand in Europe for a seasonal, lowskilled, easily exploitable workforce must be addressed. The European Union must prioritize the development of effective programmes for working visas in low-skilled sectors,26 such as seasonal agricultural work, inter alia. Indeed, the Commission itself recognizes that opening legal channels of entry to the European Union may prove to be more efficient and less costly than punitive measures, and may also contribute to a reduction in irregular migration. In this respect, the Special Rapporteu r notes that the Seasonal Workers Directive may make seasonal migration easier for low-skilled workers. He notes however that the number of visas issues under this programme will remain at the discretion of member States. A further shortcoming of the directive is that it does not provide any long-term solutions and may in fact lead to migrants ending up with irregular status if they overstay their visas. 74. Moreover, measures must be taken in order to effectively sanction employers who abuse the vulnerability of migrants, and in particular irregular migrants, by paying them low or exploitative wages and forcing them to work in dirty, difficult or dangerous conditions. In this connection, Employer Sanctions Directive (ESD) and the Victims of Crime Directive can play an important role protecting migrants in an irregular situation from exploitation. The first question of course is the full and proper implementation of these Directives in national law, and the Commission has assured the Special Rapporteur it will not hesitate to use its powers as guardian of the treaties to ensure correct and effective implementation of ESD. However, it is also imperative that the European Union invest more energy to ensure that migrants are able to access the mechanisms envisaged for their protection, without fear of systematic deportation. For example, while article 6 of ESD contains a number of provisions enabling irregular migrants to lodge complaints, these are not used in practice.27 26 27 18 For which numerous initiatives exist, e.g. the Blue Card Directive, see annex, paras. 38-39. FRA Annual Report 2012, forthcoming 2013.