It is just a matter of how you define "DRM". A lot of people don't feel the DLC-model used by ME2/DA:O to be DRM since it doesn't hinder your enjoyment of the base game at all. A lot of others consider it DRM since it involves activations and won't let you play your DLC-filled game without an active internet connection.
Can you understand why CD Projekt would want to side with the "it isn't DRM" angle? :p
I doubt anyone is going to really complain (DLC is nice), but for those who are strictly 100% no DRM whatsoever, make sure you do some research/wait to ensure that you will still count the game as 100% DRM-free.
After reading this: http://tw2.thewitcher.com/forum/index.php?topic=29225.0
And this: http://tw2.thewitcher.com/forum/index.php?topic=29226.0
I'm actually rather optimistic.
Using the three criteria:
1. This is almost exactly the same thing as EA's "Project 11 bucks" or whatever it is where they give free DLC to new buyers.
2. The key thing here is "Internet-based registration of game copies is advisable only when the developer makes available, free of charge and via the Internet, additional game content or other services requiring an Internet connection".
So we have Vernon Roche's Jacket, which is free of charge. But it requires an internet authentication at some point, otherwise GameStop or whatever will get angry. And then, this puts the framework there for when we get mini-modules that correspond to the short stories in The Last Wish (HINT, GAKKING, HINT! :p. Seriously, do this CD Projekt :p).
Or, even simpler, an online page cataloging our achievements and decisions as Geralt (sort of like the one for DA:O)
3. Again, key thing is "charges can be applied only to completely new material providing additional gameplay time".
Need I say more?
Don't get me wrong, I am still optimistic and doubt we are going to be getting any DRM model that anybody in their right mind will actively protest against (although, I expect a lot of grumbling if it uses a per-boot authentication like ME2/DA:O). But, like I said, people who are militantly anti-DRM should make sure that they don't consider this model to count as DRM.