Ultimately its Valve's decision not ours with Halloween items whether they get restricted or not.

although given how extra this one is I'm guessing it probably would be restricted.

I think this item has issues with how much it takes away team colour, sorta similar to issues with the Bushmann's.

The coat is basically evaporated away and only the gloves are left effectively, plus some muted, team-specific colours like the belt and pants.

Some further identifiers of team colours would help, since it's not impossible for things like the hands or other parts of the body to be hidden and to not know what team someone wearing this could be on.

Having the Medic's logo be etched in the appropriate team colour in the shoulders (where it normally is on the overcoat) could help, but I'm not sure what else you could do.