It sounds like regardless of JAR/EASA that if the national authority wants to allow something it goes ahead and just does it!
so if ADAC operate under their national authority regulations are you saying they do train every 6 months from their aircraft? and is the aircraft SSE/Group A performance throughout ie do they strip it out?
It sounds like ADAC are relying on their crew members experience for their winching operations and that they winch alot, rather than continuation training because of lack of "real" winches, which is great if you have that experience to fall back on.