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

Pine

--

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
                                          
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