I think you have made some great arguments, however, I believe that the UK and EEU have put out guidance on these issues. there are millions of games available on smart phones, consoles, etc. that have free packs that you can get. the burden for many of these smaller companies that create games would be crazy. Thus, the official legal advice I have seen says that it must only be followed for packs you purchase for real money. with that being said it should be really easy for EA to add this information to all packs since they already have it for store packs.
