Actually, seems to me it's more like the idea of a Fully General Counterargument. But

Your counterargument should distinguish good arguments from bad arguments, in that it specifies criteria that systematically apply to a class of bad arguments but not to good arguments. And those criteria should be matched up with details of the allegedly bad argument.

hasn't been stated so plainly before (AFAIK), and is a good point – a definition of what isn't Fully General.

Well, it intersects rationalist taboo, in that if you avoid the problem I describe, you should be able to communicate your objection without naming any fallacy. However, the more general concept of a vague counterargument can apply in situations when you are not sure what word to taboo to fix the problem. And taboo can solve other unrelated problems, such as people arguing whether sound is acoustic vibrations or sensations.