It is wrong to say that EU minimum detention standards would duplicate European Prison Rules of the Council of Europe. And this for two reasons: from a formal point of view, EU standards, if they were to take the form of a Directive, could be binding; from a substantive point of view, the EPR, having to cover all Coe Countries, inevitably have lower minimum standards. In any case, the recent agreement between Denmark and Kosovo for the transfer of prisoners, with the lowering of safeguards it entails, shows that the EPR are not enough.