I'm forwarding a reply from Maggie Dennis with her permission.

Pine

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Hi, Pine.

I've had a chance to speak to one of the attorneys, and evidently this document is in the early draft phase. It is still open to public comment and is expected to undergo revisions in Brussels in early November 2012. The final documents will probably be published sometime in early to mid-2013. Our legal team is aware of and following the situation, but can't predict the risk for these reasons.

If you haven't already (I don't have access to the list), you might want to consider joining the Advocacy Advisors mailing list. It's a bit quiet at the moment, but there are occasional bulletins or comments. https://lists.wikimedia.org/mailman/listinfo/advocacy_advisors It's a good place to monitor if you want to keep an eye on items of concern or to share your thoughts about them, including urging the legal team (who watch that list closely) to look into matters.

Maggie