I'd love to reframe this question a little bit.
You're driving a TM3 RWD with Tesla approved winter tires that displays no regenerative issues. Approaching a light doing 80km/h (the speed limit), you unknowingly find yourself on black ice. When you let go of the accelerator, the car detects the tires slipping and doesn't active regenerative breaking to prevent the loss of traction (as designed). What do you want the car to do? Regenerate and spin? Break for you? Beep? Not do anything, and let you take the next action you want to take (apply break, swerve to avoid cars, etc..?)
This seems like a complex problem. I had Nokian R2 tires on my RWD high-performance car. The car never accelerated properly on dry pavement at temperatures around freezing and upwards. The car detected traction issues, and I could have floored it all I wanted to get on the highway, but there'd be no acceleration from the car. I learned that in warmer temperatures, I'd have to slowly accelerate unto the highway, and I was aware of it and avoided situations where I needed high-acceleration passing under those conditions. I didn't go to BMW to tell them they're wrong (I also didn't use BMW-approved tires).
It's different with breaking, of course. I'm not saying there's not a problem to be fixed here. There is. But I am saying that for those frustrated, this is a difficult problem to fix. Where do you cancel out the cars slip detection with rubber compound? Is the Nokian R3 the right tire for a car that has strong regenerative breaking for the way you drive in the conditions you drive? (I understand there have been reports of it happening with "Tesla approved" tires but does seem more prominent with the R3s.)
Temperature will absolutely help mitigate this. In January and February I never had a problem with my old RWD accelerating. But I always put those tires in late, and took them off early, because I was avoiding the 'slightly or more above zero' weather. Eventually I decided that (for me, I'm not making any decisions for you) with how frequently I drive and the frequent temperature changes in Toronto, winter tires that aren't quite as good as the R3s were better choice because I, overall, felt safer in a car that performed consistently (and I rarely ever drive on snow, and have the option of avoiding it, so really I didn't have the need for them). Saying that, driving the RWD car with Nokian R2 tires no matter how bad the snow got was amazing. They really are terrific tires! But for me, it's situational, and it's a situation I could (generally) avoid.
There's a problem. It's a hard one to fix. Be prepared for regenerative breaking not to activate because road conditions don't allow for it. And yes, absolutely, Tesla should tell drivers regenerative breaking doesn't work with certain (or all) winter tires because damn, that's dangerous when you experience it for the first time.
