Rec 19/13 is irrelevant since the PLOG fuel was calculated for the 'further' div. The fact that the crew did either not realise the facts due to the 'minimum' CMR 2000kg policy, or did not think about the sensible option compounded the problem.
I think someone else has raised the point that you cannot 'blame' RY for encouraging EU 'policy' on fuel - it is this itself that needs the focus.
It would be interesting to see what (if anything) RY have done since in 'instructions' and 'guidelines' to crews.