> routed through a separate gateway. Unfortunately, this gateway's IP
> address is heavily compromised and listed on the Spamhaus blacklist.

On specific request from GMX.

> Isn't GMX's approach to spam prevention for non-European regions
> overly simplistic and potentially harmful to legitimate users?

That is a question you have to ask them.

> Does anyone else think that GMX's anti-spam measures for outgoing
> emails from outside Europe are a bit too blunt and potentially
> counterproductive?

"A) The email message(s) you are sending has been erroneously classified
 as spam by GMX. As a result your email was delivered by GMX mail systems
 that exclusively delivers emails that have been internally classified
 by GMX as spam."

It points you at  https://postmaster.gmx.net/en/case?c=uar 

Have you done this?

Best,
-- 
Atro Tossavainen, Founder, Partner
Koli-Lõks OÜ (reg. no. 12815457, VAT ID EE101811635)
Tallinn, Estonia
tel. +372-5883-4269, https://www.koliloks.eu/
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