That really doesn't change their point. It's only slightly less ridiculous, but still completely unworkable and obviously against the spirit of the regulation.

I say spirit of the regulation because I'm not a lawyer and don't want to make absolute claims about the law as written, and I trust the EU to close any loopholes that may arise.

I’ve actually come to the conclusion Apple has stopped behaving rationally here, they are behaving quite erratically.