It is unfortunate that this issue of the RAA not applying to resellers unless explicitly mentioned had not been raised by ICANN staff prior to the recommendations being finalized. If it had been, the WG might have chosen to replace"
"If the Registrar operates a website for registration or renewal," with "If a website is operated for registration or renewal,".The latter, by not saying who operates the website, would hopefully apply to registrars as well as their resellers. Moreover, it would apply to "nested" resellers (that is resellers of resellers). It is not clear if 4.1.2 and 4.2.3 apply to such nested resellers (since the wording refers to just the "resellers of registrars")
I also noticed one other error in the draft ERRP that I should have caught earlier. The PEDNR Recommendation 5 implementation is not accurate. Recommendation 5 read:
The registration agreement must include or point to any fee(s) charged for the postexpiration renewal of a domain name. If the Registrar operates a website for registration or renewal, it should state, both at the time of registration and in a clear place on its website, any fee(s) charged for the post-expiration renewal of a domain name or the recovery of a domain name during the Redemption Grace Period.
4.1 and 4.1.1 together imply that having the renewal price on the website at the time of registration is sufficient, but does not imply that the renewal price must be stated at the time of registration.