Hi Octobox
As you say, the EGR is vacuum operated and is open loop, i.e. there is no feedback to the ECU that it has "done what it has been told". I suspect therefore that the percentage figures reported are simply the demand signal sent to the solenoid valve. If the valve is all free moving and the valve, cooler and pipework are clean (and no-one has fitted a blanking plate), it suggests that the EGR valve is not the cause of the P0404 code.
I'm sorry I can't be more specific about the fault code, because there is little or no public domain information on this topic. Fiat are free to assign the generic P0404 code to something slightly different in meaning of their own making.
I suspect that the ECU monitors and processes signals from other sensors such as the MAP and MAF, in order to see if EGR operation is within acceptable limits. Effectively this is an indirect measurement, since the vacuum operated EGR isn't able to be monitored directly. This could lead to a P0404 code being thrown if there was a faulty sensor, or possibly if there was a problem with the throttle body (this also plays a part in EGR operation) though this is more likely to throw a P0638 code. The throttle body is another example of an actuator with no feedback pot (in the Ducato application) and is also operated open loop.
I must stress that the above is based on my surmise, and is offered in the hope that it might shed some light.