I too got the impression that the "Digital Content" section referred more to companies like Steam selling digital downloads. But I'm no lawyer.

It is usual for UK legislation to have one or more interpretation clauses that supply definitions of key terms.

In this case, Regulation 5 defines "digital content" as "data which are produced and supplied in digital form". Regulation 37 about "digital content" would therefore cover products such as downloadable music and e-books, as well as online movie rentals.

Telecommunications services would be a service, which comes under Regulation 36.