BBC Radio 4’s “You and Yours” explained the situation a couple of weeks ago. Apparently, each EU country has been allowed to interpret the new regulations as they see fit and to grant exemptions as they see fit. The CAA have decided not to grant any exemptions to UK registered aircraft.
As ever, in the UK, EU directives are always applied in their harshest form. Many other EU countries apply such directives as lightly as possible.