If you reside within the EEA, yes. However, given the "wink wink", the answer might be no.
Meta is requiring that people reside within the EEA, not just are someone who is an EU citizen. They're requiring integrating services to give them the IP addresses of users and for the integrating service to confirm that you're within the EEA at least once in any 60 day period. If Meta thinks you're violating that as a user, they'll cut you off from the integration. If they think the integrating service is just violating it, they'll cut off the integrating service.
It looks like Meta might be requiring as much identifying information about you as they can get so it will probably be relatively easy for Meta to figure out who is cheating.
But if you're not trying to cheat, then yes you'd be able to message US WhatsApp users from a non-WhatsApp account in the EU.
Meta is requiring that people reside within the EEA, not just are someone who is an EU citizen. They're requiring integrating services to give them the IP addresses of users and for the integrating service to confirm that you're within the EEA at least once in any 60 day period. If Meta thinks you're violating that as a user, they'll cut you off from the integration. If they think the integrating service is just violating it, they'll cut off the integrating service.
It looks like Meta might be requiring as much identifying information about you as they can get so it will probably be relatively easy for Meta to figure out who is cheating.
But if you're not trying to cheat, then yes you'd be able to message US WhatsApp users from a non-WhatsApp account in the EU.