European States’ Obligations to Repatriate the Children Detained in Camps in Northeast Syria voluntary and forced, is a war crime. 443 International Criminal Court jurisprudence notes that, in the context of children in armed conflict, the line between voluntary and forced recruitment is “legally irrelevant” and “practically superficial” given that children under the age of 15 are unable to give genuine and informed consent when enlisting in an armed group. 444 Notably, international human rights law bans armed groups from recruiting or using in hostilities persons under the age of 18 under any circumstances 445 and places an obligation on States to take “feasible measures” to ensure that persons under the age of 18 do not take direct part in hostilities. 446 Significantly, not all “child soldiers” who join, or find themselves part of, an armed group are used as fighters. The variety of the roles children undertake in armed groups are recognized in the Paris Principles and Guidelines on Children Associated with Armed Forces or Armed Groups, which instead of using the term “child soldiers” employs the more nuanced terminology: “children associated with armed groups,” which encompasses any person under the age of 18 who has been recruited or used by an armed group in any capacity, including as fighters, cooks, porters, messengers, spies, or for sexual purposes.447 In general, children can become associated with armed groups in a number of ways: abduction or coerced conscription, enlisting, or being born into the groups.448 The recruitment and militarization of children was part of ISIS’s strategy to ensure continuation of the Caliphate as both a physical and ideological resource.449 Studies show that between 2015 and 2016, more than 443 International Criminal Court (“ICC”), “Rome Statute,” Articles 8(2)(b)(xxvi) and 8(2)(e)(vii). 444 ICC, “Prosecutor v. Thomas Lubanga Dyilo,” Judgment pursuant to Article 74 of the Statute, ICC-01/04- 01/06-2842, T.Ch. I, 5 April 2012, para. 612-613. UN, “Optional Protocol to the Convention on the Rights of the Child on the Involvement of Children in Armed Conflict,” 25 May 2000, A/RES/54/263, Article 4(1). 446 The CRC Article 38 refers to persons under the age of 15, whereas Article 1 of the “Optional Protocol to the Convention on the Rights of the Child on the Involvement of Children in Armed Conflict” refers to persons under the age of 18. 447 UNICEF, “The Paris Principles: Principles and Guidelines on Children Associated with Armed Forces or Armed Groups,” 2007, para. 2(1). 448 Marc Drumbl, “Reimagining Child Soldiers in International Law and Policy,” 2012, Oxford University Press; John Horgan and Mia Bloom, “This Is How The Islamic State Manufactures Child Militants,” Vice News RSS, 8 July 2015. 449 Human Rights Council, “Report of the Independent International Commission of Inquiry on Syria,” A/HRC/27/60, 2014, para. 95. National Coordinator for Security and Counterterrorism and the General Intelligence and Security Service, “The Children of ISIS: The Indoctrination of Minors in ISIS-Held Territory,” 26 April 2017; Gina Vale, “Cubs in the Lions’ Den: Indoctrination and Recruitment of Children within Islamic State Territory,” 2018. 445 76