... "shocking" might be a too strong expression. I would rather suggest "puzzled" or "bestranged" instead.
Well, it is an open secret that a part of the industry is in conflict with the COSC since years. The reasons for tjhis are unclear to me; is it the fact that large manufacturers like Rolex, Breitling and Omega are represented in the COSC's administrative council, while smaller ones are not, or is it a claimed lack of flexibility, I don't know.
As a matter of fact, many companies decided not to send any movements to the COSC for certification. However, they did not choose to call their watches "chronometer".
The "Black Sea" is not the first UN sold as chronometer without COSC certificate. Three years ago, the "Black Ocean" (the stealth Diver) was the first.
Regarding the COSC testing procedures: I do not want to doubt your information, but as far as I know, the COSC still is testing only the naked movements. I have seen the special dials produced for the movements sent to the COSC. I know that the Qualité Fleurier is testing the complete watch, but demands all movements used to be certified by the COSC. One thing has changed at the COSC for sure, though: Unlike several years ago, when only the base movements, without any additional modules were tested, now the complete movement, as it is delivered to the customer, has to be sent. As a consequence, moficiation modules, like indirect small or central seconds, chronograph, calendar and chiming modules have to be added to the base movements before being sent to COSC.
An independent test insitute makes sense, officially, the COSC is such an institute. As long as Switzerland is not an EU member state, sending watches to Besancon or Kew for testing is a PITA (pain in the a**).
The easiest solution, imho, would be if UN applied for the official certification that they are testing chronometers according to ISO 3159. this they can prove to the customers by an own certificate.
Regards,
Marcus