This isn’t going to fly with the EU.
If the EU didn't want to allow this then they should have written the law differently, but poorly-written regulations are their specialty. Apple's plan complies with the letter of the law. Developers are free to use a direct sales channel and can offer any price they want, along with various conditions that aren't an option in the App Store. They just have to pay a commission for access to the lucrative market Apple built. The specific percentage of the commission is such that it's not actually a desirable option for developers, but the law didn't say that Apple had to make it desirable to avoid the App Store's existing sales system.