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This article contains quite a few technical terms, which I will explain these in the following paragraphs, those that are already familiar with these terms may skip to the next section. A basic understanding of linux and it’s desktop environments is assumed.
Server side decorations (SSD) is the term for when when the application’s titlebar is drawn by the system and client side decorations (CSD) is the term for when the applications draws it’s own titlebar. KDE prefers the former, while GNOME prefers the latter. KDE and most other desktop environments supports both, while GNOME only supports CSD.
Even in this case I’d argue that on small screens most apps simply have no real decorations (not even client-side)… there’s typically not even a close button. Hamburger buttons are menus, which isn’t what’s typically considered “decoration”. One could argue that the bar at the bottom in Android with home/back/etc controls is effectively a form of SSD. Android offers system UI or gestures to send the app to the background (ie. minimize) or closing it, it does not require Apps to render their own, which is effectively what Gnome is asking with CSD.