Bob
The recommendation provides guidance to - exact words - 'pilots who operate using GPS for navigation' and 'GPS for VFR navigation.'
It does not state they need to be GPS qualified, nor does it indicate whether primary means navigation or just mother's little helper.
Both CASA and Airservices recognise that many many pilots are using handhelds with high accuracy, terrain alert, etc and that they need not necessarily be certified GPS operators.
The instruction is a safety message to any pilot - even those not using GPS - to avoid flying straight down the dotted line.
I think you are splitting hairs.