I don't see how this is related to whether or not CCGs or loot boxes are gambling.
- "heavily advertised" is not necessarily a feature of gambling - Being able to easily resell reminds me of poker chips. - The longevity of the prize is not a requirement for gambling. - CCG could be instant gratification too. Time delay is not a feature of gambling.
Think of it as a "boiling the frog" situation. The fact that this is close to CCGs, and CCGs haven't been banned, doesn't necessarily mean that it's just fine - it's a slow, gradual increase in "water temperature for the frog" that's has over time become unacceptable. So it's going to be equated to gambling and regulated - obviously, there needs to be a line somewhere through that fuzzy, gradual, unclear border, but IMHO it remains to be seen whether that line will be above or below current CCGs.
I'm not sure I'm ready to sacrifice CCGs on the altar of "think of the children!" just because it might knock game companies down a peg.
Well, it's not like anyone asked horse racing or poker enthusiasts if they're ready to sacrifice anything before their games were regulated.
In which case, I am completely against this legislation. The supposed harm being addressed is nebulous, if it even exists.
There's not a bright line between CCGs, scratchcards and loot boxes.
CCGs have merely been overlooked by regulators because they've traditionally been a niche interest and none of the makers were dumb enough to decorate the card packs with one-armed bandits.
Games with loot boxes will constantly push them: Throw a loot box in your face while you play or at the end of the match, urging you to pay to open them. What's inside? Maybe something cool? Don't you want to find out? They will also typically show that you have "(3) Unopened Boxes" in your account when you are in the menus. With a CCG, I can browse my collection, play games with friends, or even tournaments, without having to turn down constant sales pitches.
Games with loot boxes often remind you, while you play, that this and that player in your game or your friend X just opened a loot box now and got something cool.
Anything you want in a CCG can be traded or bought fairly from other players. Few loot box implementations allow this.
Any duplicates you get in a CCG can be re-sold, or given away. Few loot box implementations allow this.
Any cards you get from a CCG have a physical presence, so you can store them in a box in the basement and dig them out again years later to either play or sell. Most loot box games will be dead in 5 years.
Opening a loot box is instant gratification. One click and fireworks you have spent the money and it's opening. CCGs require either mail order or physically going to a store. The time delay between feeling the urge and getting the crackle kaboom whoosh (loot boxes opening is very showy) of opening the thing is days or hours versus split seconds.