The deactivation regulation is a separate piece of legislation and follows a different route. It does not necessitates of Parliamentary or Council approval as the Commission was already empowered to set standards in the matter. And their standards as you can see in the regulations are even worse than the current Italian ones (which are the worst in the EU).
The regulation (which, different than a directive, is self-applying and does not necessitates member states' laws to implement its contents) was adopted, published, will enter into force next month and its provisions on what constitutes a deactivated firearm will apply to all deactivations performed after April 8, 2016.
In sum: as for deacts, the regulation sets forth the "minimum" technical standards to consider a firearm deactivated; the directive defines the way deacts are treated within the EU. The two things are obviously connected but are not the same thing.
Please note:
a) deactivated firearms are not one and the same with what the Commission defines as ""salute and acoustic weapons" (firearms specifically converted for the sole use of firing blanks, for use in theatre performances, photographic sessions, movies and television recordings).
So the movie industry will not come to our help.
b) even if reenacting could be construed as being a "performance" when in public, there would still be a problem because "a deact is a deact is a deact". Anything else, you need a different type of owner's permission.
c) finally, I don't think you can "opt out" from a Regulation. As I said, a EU Regulation is a very different animal than a EU Directive.
Only way out of this one is to get out of the EU