Treaties, States Parties and Commentaries
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Commentary of 2020 
Article 72 : Relief shipments: General principles
Text of the provision*
(1) Prisoners of war shall be allowed to receive by post or by any other means individual parcels or collective shipments containing, in particular, foodstuffs, clothing, medical supplies and articles of a religious, educational or recreational character which may meet their needs, including books, devotional articles, scientific equipment, examination papers, musical instruments, sports outfits and materials allowing prisoners of war to pursue their studies or their cultural activities.
(2) Such shipments shall in no way free the Detaining Power from the obligations imposed upon it by virtue of the present Convention.
(3) The only limits which may be placed on these shipments shall be those proposed by the Protecting Power in the interest of the prisoners themselves, or by the International Committee of the Red Cross or any other organization giving assistance to the prisoners, in respect of their own shipments only, on account of exceptional strain on transport or communications.
(4) The conditions for the sending of individual parcels and collective relief shall, if necessary, be the subject of special agreements between the Powers concerned, which may in no case delay the receipt by the prisoners of relief supplies. Books may not be included in parcels of clothing and foodstuffs. Medical supplies shall, as a rule, be sent in collective parcels.
* Paragraph numbers have been added for ease of reference.
Reservations or declarations
None
Contents

A. Introduction
3223  Article 72 is the first of a series of provisions (Articles 72–76) regulating relief shipments for prisoners of war. These shipments may contain tangible goods of a diverse nature, which all have in common that the person or entity sending them (family, friends, relief societies, the Power to which they belong, etc.) wishes to render the prisoner’s daily existence more pleasant or meaningful.
3224  Articles 72–76 should be read together with, but distinguished from, the provisions regulating correspondence (Article 71); religious, intellectual and physical activities, the exercise of which may be facilitated by the goods contained in the relief shipments (Articles 34, 38 and 125); and remittances of money to prisoners of war (Article 63). Were military operations to prevent the Powers concerned from fulfilling their obligations to assure the transport of relief shipments covered by Article 72, special means of transport may be organized in accordance with Article 75.
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B. Historical background
3225  Article 16 of the 1907 Hague Regulations read, in relevant part:
[V]aluables, as well as parcels by post, intended for prisoners of war, or dispatched by them, shall be exempt from all postal duties in the countries of origin and destination, as well as in the countries they pass through.
Presents and relief in kind for prisoners of war shall be admitted free of all import or other duties, as well as of payments for carriage by the State railways.
While it approached the issue from the angle of exemption from postal, import and other duties (a topic now addressed in Article 74 of the Third Convention), this provision implied that parcels might be sent to or by prisoners of war.[1]
3226  Using language which makes that point unequivocally clear, Article 37 of the 1929 Geneva Convention on Prisoners of War read: ‘Prisoners of war shall be authorized to receive individually postal parcels containing foodstuffs and other articles intended for consumption or clothing. The parcels shall be delivered to the addressees and a receipt given.’ Similarly, the first paragraph of Article 39 read: ‘Prisoners of war shall be permitted to receive individually consignments of books which may be subject to censorship.’ The aspect of censorship is now addressed in Article 76 of the Third Convention.
3227  During the Second World War, extensive schemes were developed to send relief parcels to prisoners of war. The practical implementation of Article 37 of the 1929 Convention turned out to be problematic, however, particularly in view of the entitlement of prisoners of war to receive parcels ‘individually’. Numerous difficulties arose in terms of the distribution of the parcels to their addressees. Furthermore, there was resentment between the prisoners of war themselves (some received a lot of parcels, others none), as well as from the civilian population subjected to food rationing. As a result of these difficulties, despite the absence of any legal basis in the 1929 Convention, both Detaining Powers and Powers on which the prisoners depended started imposing restrictions on the number of parcels that could be sent.[2]
3228  The practical difficulties notwithstanding, the principle underlying Article 37 of the 1929 Convention, i.e. the right of each prisoner of war to individually receive relief parcels, was never questioned before and during the Diplomatic Conference in 1949.[3]
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C. Paragraph 1: Entitlement to receive individual parcels and collective shipments
1. The entitlement
3229  Article 72(1) confers on each prisoner of war an entitlement ‘to receive by post or by any other means individual parcels or collective shipments’.
3230  This entitlement is not preconditioned on any need: it is the prisoners’ right to receive parcels addressed to them. This right may only be restricted on the basis of paragraph 3 of this provision and subject to the Detaining Power’s right to censor and examine parcels on the basis of Article 76.[4] In practice, that right may be an important impediment to a prisoner of war’s ability to enjoy the exercise of the entitlement granted in Article 72(1).[5]
3231  Two forms of relief are possible under Article 72: ‘individual parcels’, i.e. parcels addressed to a prisoner of war by name (sent by family or friends); and ‘collective shipments’, i.e. not bearing the name of a particular beneficiary.[6] The latter category did not feature in the 1929 Convention, but, in view of the numerous practical difficulties that arose during the Second World War with regard to individual parcels, a practice of sending collective relief shipments to prisoners of war developed, without any specific legal basis.[7] Article 73 regulates how collective shipments are to be received and distributed among the prisoners of war. The Third Convention expresses no preference between the two categories of relief shipments, the ratio of which will therefore depend exclusively on the private initiative of those sending them.[8]
3232  Both individual parcels and collective shipments may be sent ‘by post or by any other means’. The words ‘any other means’ may refer to modes of delivery such as private transport companies. Applicable regulations may limit the size or weight of parcels sent by the regular postal services. Thus, for example for large parcels, private courier and parcel services may be used. In all instances, Article 74 regulates the exemption of such shipments from a variety of dues. Should military operations prevent transport by either of the means referred to in Article 72(1), Article 75 foresees other options.
3233  Article 72 does not specify whether a prisoner of war needs to sign a receipt when receiving an individual parcel or a portion of a collective parcel. In the Third Convention, this question is only regulated with regard to relief supplies and material from relief societies covered by Article 125.[9] In practice, as a way of demonstrating that it has implemented its obligations under the Third Convention, i.e. that its agents did not keep the parcels’ contents for themselves but ensured they reached their intended beneficiaries, a Detaining Power may require that a prisoner of war sign a receipt.[10] The receipt must be in a language the prisoner understands. In parallel, a donor, or the postal or transport services that delivered the relief parcel, may also require a receipt to be signed, either by the Detaining Power or by the addressee. In practice, the activities of the Protecting Power, the ICRC or an organization acting on the basis of Articles 9 or 125 may also include ensuring that each relief parcel reaches its intended beneficiary.[11]
3234  Once prisoners of war receive their (portion of a) parcel which has been cleared for distribution, it becomes their property,[12] protected as ‘articles of personal use’ in the sense of Article 18(1). Thus, it is prohibited for a Detaining Power to allow relief parcels to reach the prisoners of war at first, and then to take them back once those supervising the distribution have left the camp.[13] The ICRC has observed this occurring in a number of contexts.
3235  Relief parcels sent to prisoners of war undergoing confinement as a disciplinary punishment may be withheld from them until the completion of their punishment.[14] Prisoners serving a judicial sentence are entitled to receive at least one relief parcel per month.[15]
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2. Contents of the parcels
3236  First, relief parcels sent to prisoners of war may contain ‘foodstuffs, clothing [and] medical supplies’. With regard to the last category, which previous drafts of the Convention referred to as ‘medicaments’,[16] Article 72(4) stipulates that they ‘shall, as a rule, be sent in collective parcels’.
3237  Second, relief parcels may contain ‘articles of a religious, educational or recreational character which may meet [prisoners of war’s] needs’. The Convention expressly states that such articles include ‘books, devotional articles, scientific equipment, examination papers, musical instruments, sports outfits and materials allowing prisoners of war to pursue their studies or their cultural activities’. The exercise of these pursuits is regulated in Articles 34 and 38. With regard to books, Article 72(4) stipulates that they ‘may not be included in parcels of clothing and foodstuffs’.[17]
3238  As indicated by the words ‘in particular’, the list of goods mentioned in Article 72(1) is merely illustrative and must be viewed in the light of the prisoners’ ‘needs’. As the list is not exhaustive, goods not explicitly mentioned may also be sent, subject only to the provisions of Article 76 on censorship and examination. To avoid potential problems, the Detaining Power should publish a list of items that it will not accept as part of relief consignments for prisoners of war.[18]
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D. Paragraph 2: The Detaining Power remains bound by the Third Convention
3239  Article 72(2) contains a safeguard clause: the fact that family, friends, relief societies, the Power on which they depend or others send relief supplies to prisoners of war does not relieve the Detaining Power of its obligations under the Third Convention, regardless of whether some or all the prisoners of war have received relief shipments on the basis of Article 72. Indeed, the Convention imposes obligations on the Detaining Power that may require it to provide prisoners of war with the same types of goods contained in the relief parcels sent to them on the basis of Article 72. The relief parcels may only be seen as complementary to the Detaining Power’s obligations.[19]
3240  Relevant to relief parcels containing ‘foodstuffs, clothing [and] medical supplies’ is, first and foremost, Article 15 (the duty to ‘provide free of charge for [prisoners of war’s] maintenance and for the medical attention required by their health’), a provision expanded on in Article 26 (food), Article 27 (clothing), Article 28 (canteens, where prisoners of war can buy ‘ordinary articles in daily use’) and Article 30 (medical attention). Relevant to relief parcels containing ‘articles of a religious, educational or recreational character which may meet [prisoners of war’s] needs’ are Article 34 (religious duties) and Article 38 (intellectual, educational and recreational pursuits, sports and games, for which the Detaining Power itself ‘shall take the measures necessary to ensure the exercise thereof by providing [prisoners of war] with adequate premises and necessary equipment’). Again, items of this nature in relief shipments sent on the basis of Article 72 are merely to complement those that the Detaining Power must provide anyway free of charge to prisoners of war.
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E. Paragraph 3: Limits which may be placed on the parcels and shipments
3241  Article 72(3) allows for limits to be placed on relief shipments. However, in order to avoid arbitrariness,[20] the Detaining Power may never place such limits itself, no matter the validity of the reasons invoked.[21] Indeed, the Detaining Power should encourage third parties to send parcels in the sense of Article 72, their contents being a way to enhance prisoners’ well-being and thus, in all likelihood, the stability of daily life in the prisoner-of-war camp. The foregoing is without prejudice to the Detaining Power’s right to examine consignments – once they are received − on the basis of Article 76.
3242  Only two types of entities are entitled to propose placing limits on relief shipments sent on the basis of Article 72. This entitlement is contingent upon there being a need for limits, and the limits may only relate to the scope of the relief shipment. In practice, nothing prohibits the Detaining Power from seeking to convince those entities that limits are called for, for example in the case of an unmanageable number of parcels.
3243  First of the two types of entities that may propose limits on relief shipments is the Protecting Power, where it has been appointed, which may do so ‘in the interest of the prisoners themselves’. This entitlement exists regardless of whether the Protecting Power plays any practical role in the provision of the relief parcels.[22] Depending on the circumstances, considerations ‘in the interest of the prisoners themselves’ may arise, such as if one or more prisoners receive disproportionally more than the others, a situation which may create resentment.[23]
3244  The second of these two types of entities is the ‘International Committee of the Red Cross or any other organization giving assistance to the prisoners’. The latter includes, but is not limited to, organizations covered by Article 125.[24] In this case, the entitlement to impose limits applies ‘in respect of their own shipments only’; in other words, one organization has no right to place limits on the shipments of another organization. However, one criterion – and the only one permissible – needs to be fulfilled, which is ‘exceptional strain on transport or communications’.
3245  In practice, it is likely that the Detaining Power will take the initiative to approach the Protecting Power or relief organization(s) concerned to request limits be imposed on the basis of Article 72(3). Absent their agreement, restrictions may also form part of a special agreement concluded on the basis of Article 72(4).[25]
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F. Paragraph 4: Conditions for sending parcels and shipments
1. Principle: Only if necessary and in a special agreement
3246  Based on Article 72(1), the Detaining Power is obliged to permit prisoners of war to receive relief parcels. While not explicitly stated in the Convention, for this to be possible it also implies an entitlement of others (family, friends, relief organizations, etc.) to send such parcels, either individually or as collective relief. Article 72(4) addresses the question whether the practical exercise of that entitlement may be made subject to conditions. Conditions may be imposed only ‘if necessary’. For example, goods may need to be sent in boxes or envelopes that meet the requirement of the Detaining Power to examine the contents on the basis of Article 76(2).[26]
3247  Any conditions must be the subject of a ‘special agreement’, which will need to comply with Article 6 (in which Article 72 is specifically mentioned), to be concluded between the Powers concerned. In most scenarios, this will be the Detaining Power and the prisoner of war’s country of origin. Thus, without prejudice to its right to unilaterally formulate a list of prohibited items as well as to apply examination and censorship in accordance with Article 76, the Detaining Power cannot unilaterally impose conditions, if needed, on the sending of relief shipments.
3248  The special agreement may not result in any delay in ‘the receipt by the prisoners of relief supplies’. Indeed, such delays may only result from any ‘limits’ imposed on the basis of Article 72(3). Furthermore, any special agreement concluded on the basis of Article 72(4) may not slow down more than they would otherwise the verification measures which the Detaining Power is entitled to employ for incoming relief shipments.[27]
3249  In addition to those contained in a special agreement, conditions for sending relief supplies may also result from rules outside the Third Convention, for example from applicable rules of international law regulating the transport and carriage of goods. Such rules may govern how parcels may be sent in general, and specific goods (medical supplies, for example) in particular. Failure to comply with such rules may result in the postal services or the transport company refusing to carry the parcels.
3250  Sending medical supplies across international borders needs to comply with the domestic legal framework of both the country of origin and the country of destination on such questions as whether a particular medication has been licensed for use in the country of destination or whether a qualified professional needs first to authorize such usage on a case-by-case basis. Thus, in practice, except for medical supplies which may be easily procured without the need for a prescription, it may be very difficult for individuals who are not medical professionals to send medical supplies to a prisoner of war.[28]
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2. Specific conditions for sending books and medical supplies
3251  Books ‘may not be included in parcels of clothing and foodstuffs’. The rationale for this rule, which is absolute, is to facilitate the practical implementation of Article 76(2): unlike other consignments, examination of ‘written or printed matter’ need not be done in the presence of the addressee.[29]
3252  Medical supplies ‘shall, as a rule, be sent in collective parcels’. The rationale for this rule, born out of practice developed during the Second World War,[30] is to ensure that medications cannot be taken without medical supervision.[31] However, based on the words ‘as a rule’, the option remains for the sender to include medical supplies in an individually addressed parcel.[32] The Detaining Power may decide – based on its right enshrined in Article 76 to examine the relief supplies – that even where it allows medical supplies to be contained in individual parcels, they may only be administered on the approval of a medically qualified person. In practice, other regulations and considerations may also affect the extent to which medical supplies may be sent in a parcel.
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Select bibliography
Hingorani, Rup C., Prisoners of War, 2nd edition, Oceana Publications, Dobbs Ferry, 1982, pp. 163–166.
Levie, Howard S., Prisoners of War in International Armed Conflict, International Law Studies Series, U.S. Naval War College, Vol. 59, 1977, pp. 97–212, at 158–161.

1 - For further information on practice during the First World War, see Levie, p. 159, and Sébastien Farré, Colis de guerre : Secours alimentaire et organisations humanitaires, 1914–1917, Presses universitaires de Rennes, 2014.
2 - For an account of the ‘immense scale of relief work for prisoners of war’ carried out during the Second World War, see ICRC, Report of the International Committee of the Red Cross on its Activities during the Second World War (September 1, 1939–June 30, 1947), Volume III: Relief Activities, ICRC, Geneva, May 1948, in particular pp. 201–327 (quote from p. 201). For a summary of all the practical difficulties encountered in the implementation of Article 37 during the Second World War, see Preliminary Documents submitted by the ICRC to the Conference of Government Experts of 1947, pp. 102–106. See also Pictet (ed.), Commentary on the Third Geneva Convention, ICRC, 1960, p. 353, and Maurice Bretonnière, L’application de la convention de Genève aux prisonniers français en Allemagne durant la seconde guerre mondiale (typewritten thesis), Paris, 1949, pp. 232–233.
3 - Report of the Preliminary Conference of National Societies of 1946, pp. 83–84; Report of the Conference of Government Experts of 1947, p. 185; Draft Conventions submitted to the 1948 Stockholm Conference, pp. 94–95; Draft Conventions adopted by the 1948 Stockholm Conference, pp. 76–77.
4 - Restrictions may apply to prisoners of war sentenced to a penalty depriving them of their liberty, see Article 108(3).
5 - Commission conjointe chargée d’examiner les textes des projets de Conventions à soumettre à la XVIIe Conférence internationale de la Croix-Rouge (Genève, 15–16 septembre 1947), Procès-Verbaux des séances 3 et 4, p. 100: ‘Quand on étudie la réalité des faits, on doit dire qu’en dépit de 1’affirmation que le prisonnier de guerre a le droit de recevoir tous les paquets qu’il veut, on sait qu’en pratique ce n’est pas vrai. Les envois sont contingentés au départ et à l’arrivée. Le prisonnier reçoit ce que la Puissance détentrice veut bien qu’on lui remette.’ (‘In reality, when you look closely at the facts, it must be said that, despite the assertion that prisoners of war have the right to receive as many parcels as they like, we know that in practice this is not true. Shipments are subject to quotas at despatch and on arrival. Prisoners receive what the Detaining Power wants them to receive.’) See also the amendment submitted by the United Kingdom, which made the entitlement to receive parcels explicitly ‘[s]ubject to any censorship regarded as necessary by the Detaining Power’; Final Record of the Diplomatic Conference of Geneva of 1949, Vol. III, p. 77.
6 - See Preliminary Documents submitted by the ICRC to the Conference of Government Experts of 1947, p. 106, which refers to individual parcels as ‘next-of-kin parcel[s]’ and to collective relief shipments as ‘anonymous parcels, not addressed to any particular POW’.
7 - See para. 3227 of this commentary. See also Pictet (ed.), Commentary on the Third Geneva Convention, ICRC, 1960, p. 354. See also Agreement between Austria-Hungary and Italy concerning Prisoners of War and Civilians (1918), Articles 77, 79 and 80 (on collective shipments of medicines, bread and books, respectively).
8 - At the Preliminary Conference of National Societies in 1946, it was proposed that ‘the home country should fix, according to circumstances, the proportion of both individual and collective relief supplies’; Report of the Preliminary Conference of National Societies of 1946, p. 84. This proposal was not retained.
9 - See Article 125(4).
10 - Pictet (ed.), Commentary on the Third Geneva Convention, ICRC, 1960, p. 360. The second sentence of Article 37 of the 1929 Geneva Convention on Prisoners of War was explicit on this point: ‘The parcels shall be delivered to the addressees and a receipt given.’ According to Bretonnière, this rule was not generally respected during the Second World War; Maurice Bretonnière, L’application de la convention de Genève aux prisonniers français en Allemagne durant la seconde guerre mondiale (typewritten thesis), Paris, 1949, p. 234.
11 - For practice during the First World War, see Agreement between France and Germany concerning Prisoners of War (1918), Article 53; Agreement between Austria-Hungary and Italy concerning Prisoners of War and Civilians (1918), Article 78; and Agreement between the United States of America and Germany concerning Prisoners of War, Sanitary Personnel and Civilians (1918), Article 110, which provided for individual parcels without specified recipients to be dispatched in collective consignments. See also United States, Army Regulation on Enemy Prisoners, Retained Personnel, Civilian Internees and Other Detainees, 1997, para. 3-5(k)(4), and New Zealand, Military Manual, 2010, Vol. 1, para. 12.10.65.
12 - Report of the Preliminary Conference of National Societies of 1946, pp. 87–88.
13 - Following the Second World War, three Japanese officers were convicted by a British Military Court of ill-treatment of prisoners of war, including for having stolen Red Cross supplies intended for prisoners; see United Kingdom, Military Court at Singapore, Hachisuka case, Abstract of evidence, 1946, pp. 3–4.
14 - See Article 98(5).
15 - See Article 108(3).
16 - Final Record of the Diplomatic Conference of Geneva of 1949, Vol. II-B, p. 178.
17 - For details, see section F.2.
18 - For practice during the Second World War, see ICRC, Report of the International Committee of the Red Cross on its Activities during the Second World War (September 1, 1939–June 30, 1947), Volume III: Relief Activities, ICRC, Geneva, May 1948, pp. 12–13: A few months after relief work had begun, all belligerents were induced to adopt a standard list of prohibited articles, likely to facilitate escape or sabotage; these included: Coins and bank-notes; Civilian clothing, and underwear which could be used as civilian clothing (except sweaters and pullovers); Arms and instruments which could be used as weapons (large knives, scissors, etc.); Duplicators, carbon paper and tracing paper; Compasses, maps, cameras, field glasses, magnifying glasses, electric torches, telephone apparatus; Wireless transmitting and receiving sets, and spare parts; Alcoholic drinks; Acids and chemical products; Books and newspapers of a political or military character, or of suspect contents; Used wrappings; books with maps; matches.
19 - See Levie, p. 160.
20 - Final Record of the Diplomatic Conference of Geneva of 1949, Vol. II-A, pp. 286 and 569.
21 - This practice emerged during the Second World War; see para. 3227 of this commentary, and Pictet (ed.), Commentary on the Third Geneva Convention, ICRC, 1960, pp. 357–358. In response, see Report of the Preliminary Conference of National Societies of 1946, p. 84: ‘Detaining Powers shall abstain from forbidding and limiting, on their own authority, the issue of individually addressed parcels.’ Similarly, see Final Record of the Diplomatic Conference of Geneva of 1949, Vol. III, p. 77: ‘The Detaining Power shall not restrict the quantity which may be received and held by p/w [prisoners of war] collectively or individually, unless the consent of the Protecting Power be given to such restriction.’
22 - For details, including on how to proceed in case no Protecting Power or a substitute has been appointed, see Introduction, section A.1.e, in particular paras 50–51, and the commentary on Article 9, para. 1316.
23 - See also Levie, p. 161, quoting as a reason ‘in the interest of the prisoners themselves’, the ‘possible inability of systems of transportation available to the belligerents to handle the tremendous weight and bulk which relief parcels might well engender’.
24 - See Draft Conventions submitted to the 1948 Stockholm Conference, p. 95: As regards the naming of this agency, the Committee considered it preferable, in the interest of the prisoners themselves, and with due regard to the services rendered in this field by several organizations, not to make too strict a definition, but to add to the name of the Committee itself the words ‘any other agency giving assistance to the prisoners’. While excluding purely technical and commercial organizations, this expression appears broad enough to cover any relief organization, whether it be under State or private management, national or international, already existing or created for temporary purposes, and whether its humanitarian aims are of a permanent nature, or not.
25 - See Catherine Maia, Robert Kolb and Damien Scalia, La Protection des Prisonniers de Guerre en Droit International Humanitaire, Bruylant, Brussels, 2015, p. 368, and Flavia Lattanzi, ‘Humanitarian Assistance’, in Andrew Clapham, Paola Gaeta and Marco Sassòli (eds), The 1949 Geneva Conventions: A Commentary, Oxford University Press, 2015, pp. 231–255, at 246.
26 - The practice of ‘standard parcels’ emerged during the Second World War; see ICRC, Report of the International Committee of the Red Cross on its Activities during the Second World War (September 1, 1939–June 30, 1947), Volume III: Relief Activities, ICRC, Geneva, May 1948, pp. 26–27.
27 - See Catherine Maia, Robert Kolb and Damien Scalia, La Protection des Prisonniers de Guerre en Droit International Humanitaire, Bruylant, Brussels, 2015, p. 368.
28 - For guidance and best practice on this topic (on which many more rules exist), see e.g. World Health Organization, WHO Technical Report Series, No. 957, 2010, Annex 5: WHO good distribution practices for pharmaceutical products, para. 5.3, ‘Only persons or entities which are authorized to do so and/or which hold the appropriate licence should be entitled to import or export pharmaceutical products’, and para. 5.4, ‘Distributors or their agents may only distribute a pharmaceutical product within or to a country or territory if a marketing authorization or similar authorization has been granted, which allows the use of that pharmaceutical product in that country or territory’, and Interagency Guidelines – Guidelines for Medicine Donations, revised 2010, p. 8: All medicine donations should be based on an expressed need, should be relevant to the disease pattern in the recipient country, and quantities should be agreed between donor and recipient. … All donated medicines or their generic equivalents should be approved for use in the recipient country and should appear on the national list of essential medicines or equivalent or in the national standard treatment guidelines, if the NEML [National Essential Medicines List] is not updated. Or, if a national list is not available, it should appear on the WHO model lists of essential medicines, unless specifically requested otherwise and provided with a justification by the recipient.
29 - See also Army Regulation on Enemy Prisoners, Retained Personnel, Civilian Internees and Other Detainees, 1997, para. 3-5(m), which establishes that ‘books, included in parcels of clothing and foodstuffs, may be confiscated on order of the camp commander’.
30 - See Pictet (ed.), Commentary on the Third Geneva Convention, ICRC, 1960, p. 356.
31 - ICRC, Report of the International Committee of the Red Cross on its Activities during the Second World War (September 1, 1939–June 30, 1947), Volume III: Relief Activities, ICRC, Geneva, May 1948, pp. 13–14. See also United States, Law of War Manual, 2016, pp. 593–594, para. 9.20.3.2, and Flavia Lattanzi, ‘Humanitarian Assistance’, in Andrew Clapham, Paola Gaeta and Marco Sassòli (eds), The 1949 Geneva Conventions: A Commentary, Oxford University Press, 2015, pp. 231–255, at 246.
32 - See United States, Army Regulation on Enemy Prisoners, Retained Personnel, Civilian Internees and Other Detainees, 1997, para. 3-5(k)(1), which expressly establishes that it is possible for prisoners to receive medical supplies in individual parcels.