But your explanation doesn't make sense for germany, it never takes this long. Designated Survivor is delayed more than a month for us, we're only getting episode 5 this coming sunday. Other shows like Better Call Saul, Penny Dreadful, Shadowhunters or Scream are all abailable within a day after they air in the US, subbed and dubbed!
I think it's more likely the delay is the result of Netflix germany not wanting to deal with US networks irregular scheduling. For shows that don't get uploaded all at once they advertise them as "a new episode every week" and they probably want to stick to that and gave themselves a buffer to deal with ABC taking random weeks off.
German audiences are not used to three episodes, two weeks off, two episodes, one week off etc.