

The verification demand is for Google certified Android.
‘electronic information system’ means a system, including electrical or electronic equipment, capable of processing, storing or transmitting digital data;
The OS or a phone both fit that definition.
‘component’ means software or hardware intended for integration into an electronic information system;
An app fits the definition of a component.
Maybe you would have to argue that an app is not actually a component. But if it’s a stand-alone thing, then why does it rely on an OS?
I think you can make a good argument that a phone without an OS is not a system. It’s not capable of much. Maybe custom roms will remain an option.
Anyway, Google is not abusing that loophole. So, no problem. F-Droid encourages users to complain to EU lawmakers about Google being a meanie. Maybe the EU will close it anyway as part of future tech regulation.
Components “placed on the market separately” are explicitly included a being part of the product.
Let me try to gather this together:
The manufacturer, the authorised representative, the importer, the distributor, or other natural or legal person shall, on request, provide the market surveillance authorities with the name and address of any economic operator who has supplied them with a software product, including software or hardware components being placed on the market separately;