EU situation should be looked at by everyone

> The difficulty is that Debian can be both a component supplier and a seller to consumers itself; for the purposes of the CRA, me downloading a binary ISO for personal use from debian.org can count as a sale of a product (this being how the CRA intends to prevent - for example - free trials of a proprietary product, or advertising-supported products that are also free at point of distribution from being exempt from the CRA). Whether or not it counts depends on the details of the CRA.

Those clauses are clearly and explicitly defined to catch freeware/lite/ad-free/platform/base versions given out in the course of a business venture. So it does not apply at all to Debian: there is no "full" or "ad-free" version of Debian that you can get if you sign a contract, there is no business to the side that benefits from giving away the images, there's nothing at all, it's all just there. It very clearly does not fall into that category.
Debian would have to start selling access to Debian++ "now built with -O4 for extra speed!!11" and using the "slow" version to entice new customers to fall afoul of those rules.