That by/to confused me too. This is an old article from previous JAR_FCL2:
"JAR–FCL 2.205 Flight instruction (See Appendix 1 to JAR– FCL 2.205)
An applicant for an IR(H) shall have participated in a course of integrated flying training which includes training for the IR(H) (see JAR–FCL 2.165) or shall have completed an approved modular flying training course as set out in Appendix 1 to JAR–FCL 2.205. If the applicant is the holder of an IR(A) the total amount of flight instruction required by Appendix 1 to JAR–FCL 2.205 may be reduced to 10 hours. "
JR