I believe my point stands that degradation or failure prior to what is described in those standards is the responsibility of the Manufacturer.
There has been no failure, the surface is expected to degrade with time. Under MSG3 every aspect of the aircraft is inspected under the reoccurring A/B/C checks, and zonal inspection programs. All of those MPD will say the lower limit time for maintenance is not fixed, if it need to be repaired, it gets done. Likewise of some private aircraft that are hangered when not in use can often extend their repaint cycles as the hanger has protected the aircraft.
Aircraft paint and primers are customer options. The more expensive ones are less dense, adhere better with flexing, and chemical strippers can be used for repainting. The cheaper paints have to be removed by sanding, which often results in surface damage.
Also, my experience in Nuclear says that maintenance (even painting) intervals are scheduled prior to expected failure.
I’m sounding like a broken record, nothing failed.
In this case, we have reports that the surface of the panels under the paint (the non-structural "protective" layers) is also degrading.
That is expected on all composite aircraft. Prior to painting the surface is filled, then a epoxy base is applied, then the aircraft is painted. We are talking about fractions of a millimeter layers.
Look at the wording of the EASA statement and it clearly indicates both paint and protection being degraded (although not a structural or other safety issue, at this time).
This is totally expected, that protective layer is normally removed during the paint process to facilitate inspection of the surface underneath and a new layer is applied.