Even Australia, the only country which currently has an 'EIR' (the 'Private IFR'), allows the inclusion of 'Flight Procedure Authorisations' (which may include instrument approach privileges) within the Rating - most schools refuse to train for the PIFR without FPAs!
Quite what the FCL.008 NPA will include is not yet known. Extended discussion about the so-called 'EIR' at this stage is nugatory.