No, but I am aware of this, I even thought to mention it, and I sorely hope that I am proven wrong. However, my concern is that the ban explicitly does apply to the medium itself.
In particular, article 12 bans participation in "activities the object or effect of which is to circumvent prohibitions". Can you think of any reason for why Tor would not be considered to circumvent the ban?
The simplest answer to this is to look at what the previous regulation (the one being amended by this one) says[1].
Article 12 is completely unmodified except for the scope of parties involved. Since the original (2014) regulation didn't ban Tor, I think it's a safe assumption that this one doesn't either.
The more detailed answer: the article actually reads as follows:
> It shall be prohibited to participate, knowingly and intentionally, [...]
"Knowingly and intentionally" is the operative phrase here. In order to show that this article poses a threat to Tor's legality, you'd need to show at either Tor's operators or Tor itself intentionally provides service to RT. This is a stronger standard than passive service, the kind Tor actually provides.
> "Knowingly and intentionally" seems to apply to the operation (e.g. "you know that you're running a Tor node") - "circumvention" is on the basis of "object or effect". (For ESL speakers: "object" means "goal", "effect" means "result", and Tor obviously has a final, de-facto result of unblocking RT)
I responded to the second part above, below your linked comment.
For the first: broadcasting is an intentional media activity. You're right that this new regulation adds a ban, but it's not clear that said ban undermines the intent required in Article 12.
To be clear: it's a form of government censorship. But, on my reading, it's not a particularly broad form or itself a stepping stone to banning Tor. The EU seems perfectly content to broach that problem with separate regulation.
> Can you think of any reason for why Tor would not be considered to circumvent the ban?
Because plenty of people use Tor for accessing things which aren't covered by this particular ban? Sure, many of them may be illegal in other ways, but not all of them. If using Tor isn't enough in itself to prove you're buying drugs, why would it be enough to prove you're accessing banned content here?
No, but I am aware of this, I even thought to mention it, and I sorely hope that I am proven wrong. However, my concern is that the ban explicitly does apply to the medium itself.
In particular, article 12 bans participation in "activities the object or effect of which is to circumvent prohibitions". Can you think of any reason for why Tor would not be considered to circumvent the ban?