In mainland europe it is not legal to file IFR without an IFR rating. That may differ in the UK or other nations but that is outside the scope of JAR FCL and everything else under european regulation, it is purely a national thing and may change considerably come april. One of the reasons is that IFR outside CAS (i.e. class G which exists only below 2500ft AGL in some places, below 1000ft AGL in most) is not allowed. The only exception is class F which may only contain one IFR flight at a time and is only activated for that sole purpose to provide higher VFR minima (5km vis, 1500m lateral spacing to clouds and 1000ft vertical spacing to clouds).
Your description of instrument flight time is correct and straight out of the definitions of JAR-FCL, however it is something that may only be "logged" in the remarks column and is of no regulatory interest. Operation of the aircraft according a certain set of rules however is of very much regulatory interest, hence the requirement to log IFR time.