I agree with Mike above.
It really does hang on the definitions, and we haven't seen those at all. Not a hint, not a clue (that I have heard).
And as I have written, it isn't going to be easy to come up with clear definitions which catch any significant part of the foreign reg fleet - not least because it will be trivial to set up a 100% bona fide non EU operator for much of it (though not for ordinary private owners like myself).
Assuming the EU is driving this to genuinely screw the FRA fleet (rather than to p1ss off the USA into signing some treaty; a tactic which might work with Upper Volta but is unlikely to work with the USA) they will fail in screwing the most provocative part of it which is the upper end of it.