Thank you for being clear on this! As someone heavily involved in wireless keyboards, this seems to be a major point of confusion. Several folks have mentioned concerns about selling wireless keyboards in RegionX, and when I ask what they’re doing about EMC testing for their current offerings, the answer is typically “nothing”. I completely understand why that might be their current testing approach, but it also seems a bit backwards to suddenly care about it (especially since I always design w/ pre-certified modules, that have had the intentional radiator testing done, and what’s left is the same unintentional radiator testing you’d do for a non-wireless keyboard.
Appreciate the detail that went into capturing the current state of things, and at least some brainstorming on how things might be different. I do think there’s likely two different sets of folks w/ different solutions, as you note: large vendors, and smaller/niche ones, with different risks, and possible solutions (or non-solutions).