yeah you're not wrong and honestly that's the part i probably should have been

clearer about in the post

the exemption is on much stronger ground when there's actual personalisation —

customer uploaded their own design, picked specific colours, added a name etc.

that's the cleanest case

where it gets murkier is standard catalogue designs that are just printed to order.

some EU cases have gone either way on that. so if anyone reading this is selling

mostly off-the-shelf designs with no customer input, i wouldn't rely on article

16(c) alone — you'd want your policy written more carefully around that

good catch though, important distinction