Not so much interpretation in EASA:
What is the difference between 'commercial operation' and 'commercial air transport (CAT) operation'?
Reference: Regulation (EC) No 216/2008 ('the Basic Regulation'), Regulation (EU) No 965/2012 on Air Operations
The term 'commercial operation' is defined in Article 3 of the Basic Regulation as follows:
'Commercial operation' shall mean any operation of an aircraft, in return for remuneration or other valuable consideration, which is available to the public or, when not made available to the public, which is performed under a contract between an operator and a customer, where the latter has no control over the operator.
The term 'commercial air transport (CAT) operation' is defined in Article 2 of Regulation (EU) No 965/2012 as follows:
'Commercial air transport (CAT) operation' means an aircraft operation to transport passengers, cargo or mail for remuneration or other valuable consideration.
The two definitions make it clear that 'commercial operations' include 'CAT operations'.
Flight Standards | EASA
So if you´re not flying cargo or pax….you´re safe……which means ferry flights, maintenance flights….observation flights, power line checks…..
The link in german i posted above states that-as far as German CAA is concerned-spraying and other "cargo"-like flights are exempt as well…..i haven´t found an english page stating this...