Yes, I believe so, but only relays operating out of the EU.

If the relays were to block DMs, I think they should be in the clear as that's the only thing that is end to end encrypted.

The node operator **could** make the argument that the **clients** are doing the encryption and that they have no control over which clients people use, but that'd be a pretty risky legal argument, especially if there's no client in existence that could possibly comply with this law.