It feels bizarre to an American perspective. How is a company supposed to follow rules that are open to interpretation? Or does the EU think it can legislate outcomes (even if they're uneconomic) ?
In this case, Apple is dragging their feet screaming trying to do their best not to comply with the intent.
What's going to happen next, they'll get a notice of nonconformity where they're asked to fix their behaviour. If they don't show good intent, they'll get hit with a fine. If they fix it and adhere to the laws here, then we'll all end up better - well, maybe the poor shareholders won't survive this hit...
If you're a company operating in the EU, just a little bit of willingness to adhere to the laws goes a very long way.
That's the law. Not some linguistic technicalities in some document somewhere.
Apple just appears to be hard of hearing, perhaps purposely.
That's easy. Make a good faith interpretation of the intent of the law and follow that.
And don't try to find loop holes that only work in your favor.