An RCD will only detect faults downstream.
It will not detect faults upstream.
As such, in the example I gave, any earth fault current caused by a fault on the RFC will bypass the RCD and enter the special location.
As to the wording, why should it state "whole circuits"?
Why would the word circuit require a qualifier to let us know that it refers to the whole circuit?
Surely if anything would need qualyfing, it would be when only a part of a circuit is refered to?
As to the FCU being the origin of the circuit, that doesn't appear to be what Appendix 15 states.
Then of course, there's the requirement of 314.4: "Where an installation comprises more than one final circuit, each final circuit shall be connected to a separate way in a distribution board. The wiring of each final circuit shall be electrically separate from that of every other final circuit, so as to prevent the indirect energizing of a final circuit intended to be isolated."
I accept that the part of the circuit from the FCU, satisfies the definition of a circuit, as it would be "an assembly of electrical equipment supplied from the same origin and protected against overcurrent by the same protective device(s).
However, unless you wish to argue either that it is not a final circuit, or that an FCU is a DB, it will not meet the requirements of Reg. 314.4, insofar is it is not connected to a separate way in a DB.
It can be argued, that 701.411.3.3, doesn't just refer to circuits that supply equipment in the location, but also to circuits that pass through the location concealled in the walls or above the ceilings.