CRC/C/CHN/CO/3-4 the problem and develop targeted policies and programmes in mainland China and Macao, China; (b) Immediately address the issue of corruption and impunity in Macao, China as a matter of priority, through rigorous investigations of complaints of complicity by government officials and their prosecution for such crimes; (c) Take all necessary measures, legal and institutional, to strengthen identification, investigation and prosecution of foreign paedophiles in all jurisdictions of the State party, particularly in Macao, China. 90. The Committee regrets that the application of the Optional Protocol has not been extended to Hong Kong, China. 91. The Committee urges Hong Kong, China to finalize all preparations necessary so that the application of the Optional Protocol can be extended without any further delay. Administration of juvenile justice 92. The Committee welcomes the amendment to the criminal procedure code for mainland China and the current discussions on reforming the RTL programme. It remains however deeply concerned about the continued application of administrative detention of children, including RTL and work study schools, and the State party’s failure to end these practices despite repeated concerns expressed by the treaty bodies and United Nations special procedures mandate holders. It is especially concerned that: (a) Children above 16 years can be detained in RTL facilities without any access to legal safeguards or representation and that such detention can last up to 18 months, according to the State party; (b) Reports indicate that children are abducted and held incommunicado for days or months, either with their parents or in the absence of their parents or guardians, in secret detention facilities, including “black jails”; (c) No steps have been taken to investigate allegations of the existence of black jails and torture and ill-treatment, including food and sleep deprivation, of children in such places and RTL facilities; (d) Children of migrant workers are significantly overrepresented in the criminal justice system in mainland China; (e) Children, especially those in vulnerable situations, such as children in poverty, face several obstacles to access to justice, including inadequate access to legal aid and lack of independent legal aid. 93. The Committee recommends that in all areas of its jurisdiction, the State party strengthen its efforts to build a system of restorative and rehabilitative juvenile justice fully in line with the Convention, in particular articles 37, 39 and 40, the Committee’s general comment No. 10 (2007) and other relevant standards. With regard to mainland China, the Committee urges the State party to ensure that no child is deprived of his or her liberty unlawfully or arbitrarily and that the best interests of the child shall be the primary consideration in any action. The Committee further recommends that, with regard to mainland China, the State party: (a) Abolish the institutionalized system of RTL and work study schools, which allows for the widespread application of administrative detention of children; and end the use of incommunicado detention of children, including by immediately closing all secret detention facilities, such as black jails; 21