I am at a northern base where for 9 months out of the year there is snow on the ground. I have seen many people wear the APECS with these sewn on the center lower part of the flap of the pocket of the left arm. I have see many E-7 and even some E-9's wearing these as stated above. As far as I know AFI36-2903 has not been updated to mention the wear of ABU/APECS. But I have seen a CMSGT wear one on his APECS so I would say it is a safe thing to do. Hope this helped.
I'm not sure if these are authorized for wear on the APECS jacket. I've never seen any nametapes on the older BDU Gore-Tex jackets nor have I ever seen any on the APECS jackets during the past winter either. Also I'm not real sure where it would be sewn onto as there are no chest-pockets on these jackets to sew the nametape on top of. Someone please correct me if I'm wrong.