That's exactly correct.
Let me quote something from the WIPO guide on Internet treaties, which will speak to this: “...once placed on the market for such purpose,” circumvention tools and exceptions “would become available to all to use with impunity.”
You're right on here. It becomes incredibly difficult to do the work of rights holders or law enforcement to find the bad actors. Not only would you have to prove that a circumvention occurred, but you'd have to prove that a copyright infringement resulted and that this was the intent of the circumvention.
The bar becomes so high that from a practical level it becomes incredibly difficult. In particular, mid-size and small companies don't have the resources of some of the larger members to pursue these actors. It becomes incredibly difficult.