Come on you of all people should know the difference between revalidation's and renewals.
Yes, I do, and you as an examiner should understand the difference between a licence and a rating. The EASA
licence does not require revalidation, renewal or re-issue but the aircraft rating contained within it, of course, does.
In order to gain an EASA Part FCL licence or add a Class rating the the time must be logged in an EASA CofA aircraft.
It is true that the training for the issue of a class rating and the experience required for its revalidation must be gained in the same class or type (FCL.740A). However, the OP referred only to the experience requirements for the issue of an EASA licence, specifically a CPL, and that experience may be gained in any aircraft of the same category. FCL.035(a)(2)(i) clearly states:
"An applicant for a licence, rating or certificate shall be credited in full with all solo, dual instruction or PIC flight time towards the total flight time required for the licence, rating or certificate."
There is no mention of EASA CofA, Annex II or any other restriction - it simply says
all flight time.
EASA made it clear in the CRD for NPA 2008-17b that its intention was that experience for issue of a licence or rating could be gained in any aircraft whereas experience for revalidation could be gained only in an EASA aircraft. Specifically, in its response to General Comment 2420, made on the subject of crediting of flight time in Annex II aircraft by the Danish Powerflying Union, the agency stated:
"Annex II aircraft are excluded from the scope of the Basic Regulation, and the Agency cannot regulate them in detail. However, amendments to the initial proposals have been made of the crediting of experience to allow hours flown in these aircraft to be taken into account. Please see amendments to related paragraphs in Subparts B and C."
Sufficient education?