smithgd,
No, you got that right. But the IRE needs to hold an IRI rating, which makes this a mockery since the IRI needs the 800 hours IFR.
This is yet another EASA mistake. The hours requirement (200 - FI, 800 - IRI, 450 - IRE) is a copy from the JAR rules, which required any examiner to also have the ratings to instruct for what they examine. So under JAR-FCL (1.452, if you want to read it up), both an IRI and an FI with the "no applied instrument" restriction removed would have been sufficient. EASA explicitly requires an IRI. I don't think this is intentional.
On to your other point - technically, ANY flight in class G below 3000ft, clear of clouds, in sight of surface, and 800m visibility is according to IFR (and if you don't believe it, read rule 33 and 34 in the ANO, which are the IFR in class G). And of course also the departures, approaches and landings in accordance with normal aviation practice, for example, circuits.
I'd just LOVE to see anyone pitching up at the CAA and claiming substantiall ALL their flying as IFR as long as it was in Class G and below 3000ft, which includes all PPL training... EASA didn't think that one through, did they? As I wrote above, the reply will most likely be, pull the other one...