Fitter2,
I hope that you're right about the EASA certification. It would be great to have a low cost traffic alerting system fitted to all of the company aircraft.
But you seem to forget FLARM's (current) major achilles heel - it needs another FLARM box to 'talk' to. As another poster has already pointed out, until there is 'critical mass' and the majority of aircraft have FLARM fitted, then the system is of limited use. This isn't realistically going to happen unless it is mandated.
Which takes us back to transponders. You don't need me to tell you that the majority of (powered) aircraft already have these fitted. So it is reasonable to suggest that any traffic alerting system should use this current 'infrastructure' (for want of a better word.)
Also, do you accept my previous point that position reports given by aircraft wrt to VFR features are useless to other aircraft that are currently IMC?