The link you provided appears to say the opposite about kits:
"Based on the definition above, it looks clear that non-authorized kits that are intended to form a complete product when fully constructed are technically not legally permitted to be sold in the US. That is because if you are marketing and selling a kit to an end user, which the user will then build into a full product, there is no reason to suspect that the normal rules would not apply."
The subassembly rules could work, if they apply, but I don't see how this product fits the definition of a sub-assembly:
"No authorization is required for a peripheral device or a subassembly that is sold to an equipment manufacturer for further fabrication."
In fact, I think it's a stretch to say that any of these test-kit, dev equipment, or subassembly rules apply. This basically strikes me as being marketed as a consumer product -- albeit a product for very tech savvy consumers.
"Based on the definition above, it looks clear that non-authorized kits that are intended to form a complete product when fully constructed are technically not legally permitted to be sold in the US. That is because if you are marketing and selling a kit to an end user, which the user will then build into a full product, there is no reason to suspect that the normal rules would not apply."
The subassembly rules could work, if they apply, but I don't see how this product fits the definition of a sub-assembly:
"No authorization is required for a peripheral device or a subassembly that is sold to an equipment manufacturer for further fabrication."
In fact, I think it's a stretch to say that any of these test-kit, dev equipment, or subassembly rules apply. This basically strikes me as being marketed as a consumer product -- albeit a product for very tech savvy consumers.