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In order for the DFDL parser to allow an element to have a value with a length of zero and for it not to be nillable, the parser needs to support elements with the "empty representation" (section 9.2.2 in the DFDL specification) and defaulting values on parsing (section 9.4 in the DFDL specification). Implementing this capability is judged as too large to be delivered in the service stream, so it would have to be added as a new capability first. That capability can then be ported back to the service stream.
For the moment, the work around of using the "nil representation" is still the only way of getting the desired result.
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