Yes, but it misses the point of the criticism. The issue isn't whether the final product is difficult to test. It should be roughly as easy to test the final p

Yes, but it misses the point of the criticism. The issue isn't whether the final product is difficult to test. It should be roughly as easy to test the final product no matter the implementation strategy. The problem is that TDD requires a royal-road of testing. No code can be written without tests for that specific piece of code. So you can only build the whole out of components that are testable in isolation. The claim is that this excludes architectures that don't provide such a step-by-step path of testing. This interacts badly with the 'make everything an API' idea. You end up with these functionally small units with over-engineered APIs rather than something more complex, more efficient, and easier to refactor as a whole.