Everyone has to stop thinking in UK terms and start thinking from the perspective of a European licence holder who has never held an IMC rating.
Some points to pick up on;
Dublin pilot - Engine failure in IMC enroute for someone with an EIR or an IR or an IMC rating present exactly the exact same issues. It is an emergency and thus the pilot can legally do whatever they think is necessary. However, should a PPL or an EIR or an IR or an IMC rated pilot be flying in VMC over an extensive fog bank and the single engine fails then they are all faced with having to complete a forced landing in IMC with insturments that are in the process of running down due to lack of suction and limited battery life for the turn coordinator and pitot heat etc
So do you think that a basic PPL flying VFR on top or an EIR holder who at the same place and the same level has the engine problem you describe - which will be better equipped to descend through cloud and track a VOR/NDB and/or follow ATC vectors?
I do not know how people have a problem with the requirement to "guarantee VMC" at the destination.
Perhaps it is a poor choice of words?
However every VFR pilot flies on the basis that they guarantee that they will fly and land in VMC. Is the UK somehow different in this basic safety issue?
People need to have a serious look at what the UK restricts and what is permitted outside the UK (as well as what is permitted both in and outside the UK) before they comment.
For example, someone asked how I would like to share the airspace with "Brevet de Base" pilots from France. Anyone in the UK has a good opportunity of sharing class D E F and G airspace with pilots who are the UK's version of the same i.e. 15 hours limited to a radius from departure etc etc. So different? how?
What about places where to fly IFR you have to hold an IR regardless of weather conditions? Or places where you have to fly IFR at night regardless of conditions?
People must not think of the proposed rating in isolation. Operating rules (Rules of the Air) and other related licensing rules have to be taken into account.
As for "permit to fly aircraft not being certified". That is not quite true. They are certified to a certain standard - CS-VLA, Section S etc but for various reasons are not eligible for the issue of an ICAO C of A. This is often simply down to paperwork, quality assurance and records standards.
That is why the disclaimer says "Not Certified to ICAO Standards" rather than "Not Certified".
Happy flying.
Brendan