VOA Requirement for Swedish Passport Issued after January 2015

My friend is a Swedish passport holder travelling in HK. She was trying to apply for a China visa (Type L) here but was asked to submit her old passport also (which is lost) since her existing valid passport is issued after January 2015 (new application rule effective 6-Apr 2017). Is she eligible to apply for the VOA at the ports without her old passport? Thanks.