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Well, to me ecchi is only "naughty" pictures, ones where panties are visible, cleavage is showing, so forth. Seeing as condoms are explicitly sexual, I'd say /h/ material. That being said, /h/ tends to be for hard-core explicit sex (intercourse, bodily fluids, body cavities, etc), and condoms in the wrapper are much less suggestive. So they're fine in /e/.
This pic is really pushing the limits for /e/. It's not TOO explicit, but that is a "diary creamer" filled "water ballon" so, yeah, it really should probably be in /h/. Anything tamer is probably AOK.
