I disagree, what is your source? Now the planes of for ex X Fliegerkorps, which attacked RN ships in 39 and 41 belonged to LW so LW's anti-shipping units attacked already in late 39 against RN. Kriegsmarine tried to monopolice torpedo but as I wrote that wasn't only anti-shipping weapon. 40-41 many LW units operated against ships around UK etc.
Juha
Juha