particular importance for children born in a State which does not apply the jus soli principle and whose one or both parents possess a nationality, but neither can confer it upon their children. Paragraph 2 contains an important safeguard against statelessness by granting nationality to any child who does not fulfil any of the requirements set out in paragraph 1 and who would otherwise remain stateless, and paragraph 3 ensures the retroactive application of paras 1 and 2. 12. UNHCR suggests to reinstate the text of paras 2 and 3 of Article 5 of the Act currently in force to provide safeguards for children who would otherwise be stateless, as required inter alia under Articles 1 and 4 of the 1961 Convention and complementary provisions in international human rights law, including Articles 3, 7 and 8 of the Convention on the Rights of the Child.18 B. Renunciation resulting in statelessness 13. According to proposed amendments, revised Article 22(2) of the Act should read as follows: “Croatian citizenship of a child under 18 years of age, adopted by foreign citizens, shall terminate by renunciation upon the request of his or her adoptive parents.” 14. Articles 5-7 of the 1961 Convention limit loss of nationality to situations where the individual concerned possesses another nationality at the time of said loss. Article 7(1) allows renunciation of nationality only on the basis of acquisition of another nationality. According to UNHCR guidance on this matter, States which allow loss of nationality in cases of adoption of a child by a foreigner must restrict these to cases where a child acquires the nationality of the adopting parent(s) by the mere fact of the adoption and must never result in statelessness.19 UNHCR notes with concern that proposed amendments to Article 22 do not contain sufficient safeguards against statelessness in cases of renunciation of Croatian citizenship on behalf of children, including those who were adopted. 15. UNHCR suggests that revised Article 22 of the Act incorporates safeguards stipulated in Article 7(1) of the 1961 Convention, which prohibits renunciation of nationality if the individual does not possess another nationality at the moment of loss. In order to ensure states that ”[a] child who acquires Croatian citizenship pursuant to paragraph 1 or 2 of this Article is considered a Croatian citizen from the moment of his or her birth.” 18 As stated above, the Convention of the Rights of the Child (CRC) is crucial in construing the scope of the 1961 Convention obligations to prevent statelessness among children. Article 3 of the CRC sets out a general principle and also applies in conjunction with Articles 7 and 8, requiring that all actions concerning children, including in the area of nationality, must be undertaken with the best interests of the child as a primary consideration. It follows from Articles 3 and 7 of the CRC that a child must not be left stateless for an extended period of time and must therefore acquire nationality at birth or as soon as possible after birth. Article 8 of the CRC provides that every child has the right to preserve his or her identity, including nationality. 19 UNHCR, Expert Meeting - Interpreting the 1961 Statelessness Convention and Avoiding Statelessness resulting from Loss and Deprivation of Nationality ("Tunis Conclusions"), March 2014, available at: https://www.refworld.org/docid/533a754b4.html. 4