First of all: they do not always stick exactly to the law. You may receive you Residence Card a few weeks late, just as others have. There is very little you can do about this (no court would give a decision within a few weeks), but you may be able to claim damages if they were unavoidable.

My personal opinion about your question is that it is from posting the application. The reason is that they do not accept an in person application, so the posting process is actually part of the application. Whether this would stand in court is another matter, but then again cases rarely get there.

Tom