Regardless of how the proposed regulation is worded, one aspect that I have not yet seen discussed is how the original type approval (TA) values would be determined by in-service testing. TA is conducted by a small number of designated and accredited test houses under laboratory conditions and real-world simulations using complex (and expensive) equipment and measures emissions in terms of grams per kilometre. This takes some time to perform. Emissions measurements for MOT testing is quite different and I have yet to find out how MOT levels were derived from or correlate with the TA requirements.
In view of this, how would the authorities determine whether a vehicle continues to meet the levels measured by the TA assessment? DPF, Catalytic Converter or AdBlue deletion should be fairly obvious. Gaseous and particulate emissions in terms of TA (not MOT) levels is not (currently) something that can be determined at the roadside or by a MOT test station.