I'd like to place the following restrictions on all
derivative works, regardless of whether they're commercial or independent:
For-profit development of works whose main element is animation(*)
...
* By this I mean so-called "traditional cel animation"; computer-generated 3D
animation and 2D illustrations with special effects processing aren't included
in this restriction.
About one year ago, I've written about this at MotK. In short, this rule was poorly conceived. It was hastily made to shut down the Animate X Touhou project, while completely ignoring the fact that there are fan creators whose chosen medium of expression
is traditional cel animation, and who have always acted in good faith. Even if you are an amateur animator who draws your own Touhou anime using simple B&W sketches, this rule would bar you from selling it at conventions, not to mention higher profile works like Touhou Kinema Kan and Touhou PVD.
Hearing the fan outcry, ZUN revised the 2011 guideline two days after releasing it, changing this particular item to "commissioning corporations for the production of animation" (アニメーション製作を企業に依頼する行為).
EDIT:
I make the post above in my usual role as a neutral observer of the Touhou phenomenon.
As you can see, I'm associated with the Hifuu project closely enough (while being neither directly participating nor its official representative) that I'm not really the right person for making certain comments about it, positive or negative.
In any case, it probably doesn't involve "commissioning corporations for the production of animation", as far as I can tell.