PPMs in Seal Products

From the EU second written submission:





There's a policy issue here which may not have been in the drafters' minds when they wrote the definition of "technical regulation".  When you ban an input product, are you therefore regulating all finished products that use the input?

Here, the question is, does a ban on the use, in some final products, of inputs of products derived from seals (e.g., seal fur in hats or coats, seal oil in Omega-3 capsules, etc.) mean that the production of the final product is being regulated?

In some sense, such a ban means that those final products cannot contain seal inputs, and thus has an impact on the method of production. For example, Omega-3 capsules cannot be produced using seal oil.  But is this different from a measure that says, e.g., "Omega-3 capsules must be made in the following way," and then specifies a production method?  Should these two situations be treated differently under the law?