There are different levels of nonvolatile  memory implementation they are looking at,  removable and embedded.

Removable nonvolatile memory: used for file storage

They have a broad claim of removable memory with a first . The question is, will they ask for this claim alone to be  enforceable on that merit alone?

IMO...no...however,it's yet to unfold.

What,IMO, will be contested,  is the method of format by a device of the removable memory. Along with the manner in which files are created and pushed into and out of the memory. Specifically the volatile working memory method sitting in front of the nonvolatile memory.

 The removable memory market of SD,MMC, CF...to name a few, have  controller firmware(licensed:hardware/software) on board the removable module,  for SD it's Sandisk. This firmware set interacts with the read/write/erase capability of the flash within the module, combined with a volatile working memory and instruction from the calls of an OS. 

IMO...This working memory interacting with the memory module is what they will be looking at and will unfold the process of a device.

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 Embedded nonvolatile memory: used for boot, file storage, device configurations, execution.

 For this process normally its not a packaged module as the above.

A developer needs to supply the firmware(hardware/software) that interacts with the nonvolatile memory. They can go to a company like Sandisk(or e.Digital) and license,  or devise their own. With that, they also need the volatile working memory as above along with an OS the memory is to emulate. The working memory attributes are dictated by the firmware(hardware/software)abilities as it relates to the OS it recognizes.
There is a big difference in the manner in which Sandisk(with NO OS) and e.Digital implement this working memory process.

 Hope that helps a little. There's a lot more to it, however,  this is the very first incident of The process that can be recognized. It then leads to the other processes involved.

doni