That seems to be stretching it. The user is informed about the IDFA on setup (one can argue that that is a violation), so it’s not like “Apple’s operating system creates the IDFA without user’s knowledge or consent” because they do inform you.
Regardless, you can always reset it if you want. And “at” WWDC 2020 (half a year before this complaint), Apple made cross app tracking opt-in.[0]
I applaud the EU for leading the way in consumer protection, but every time I hear about it in regards to technology, it always feels heavy handed with the arguments being a stretch sometimes.
It not stretching. The ePrivacy directive requires that user _is offered the right to refuse such processing by the data controller_, so it also refers to Apple itself.
There’s an open complaint [0] about the IDFA on the same basis...
[0] https://noyb.eu/en/noyb-files-complaints-against-apples-trac...