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Loophole-proofing means doing a revision to the DMA, which means that they need to go through all of the stages again. It took three years on the first round, and they’re probably going to need a few more revisions to get all of the holes fixed.
Such is writing policy. Mayhaps it needs to be reformed down the line as well.
There is no loophole though.
Even if there was, the EU runs on civil law, not common law, which means the intent of the law trumps the wording, and there is no emphasis on precedents. So if an EU judge decides that Apple is fucking around trying to skirt the law, there is no change required to the law to slap them down.
