Would this be classed as a GNE

[RMC]

Fairly new to Long Haul.

Prior to EEP one of the ETOPS ERAs (say KEF) became unusable (went out of crosswind limits snowclosed etc).

If no replacement alternate were selected before EEP (and you had not replanned using an alternative ERA) would this be classed as a GNE or is that term strictly limited to distance off track?

Thanks in advance.