EU "law" is very complicated and even if regulations may be originally thought of "directly applicable", reality often proves this to be wrong or ignored by certain, but not always the same, EU countries.
I still don't get why the EASA system does not issue EASA-piggyback-validations to FAA license holder, the same as backwards - inner-EASA cross approval of validations shouldn't be a problem, or?
We now have two threads in parallel, the OP started another one
here. Maybe the admin can merge them?
Copied from the other thread:
The actual list of countries and their willingness to enact opt-out is documented in an Excel sheet to be found here:
opt-out-from-regulations - scroll down to downloads and get "Derogations from Regulation (EU) 1178/2011 as amended" (explanation for active enact opt-out inside the file).