There's no option to edit my previous post, but I'm just comparing the two forms more closely today and I can see that Form 12 doesn't have the 'Gain taxable at 41% (S. 747E(1)(b)(ii))' category that is on Form 11 under section 322.
The ETF manual says "Acquisition of an EU ETF must be included on the Form 11 in the Foreign Income section as appropriate."
There is a Foreign Income section on Form 12 too though, but it doesn't appear to be as in depth as Form 11.