[rdsnsca]

An added expense, for an app that may not be paid.

[lapcat]

If your app is not paid, then you're not a "trader" according to the EU.

[throw4950sh06]

You are according to the EU's rules of digital markets. Any app provider is.

If you don't process any personal information, don't have ads or purchases and don't have online backend services... Then you might have a chance of arguing you're not a business. But that's probably so few apps it's worth it to just require everyone to follow the same rules.