I asked search engines with AI today a question about who was the copyright holder for the embedded operating system inside SecureDigital (SD) flash memory cards. The answer was that the individual card manufacturers develop their own operating systems that comply with SD Card Association specifications. This is interesting as an SD Card contains and operating system of limited scope, is a mobile device and is a general purpose computing device. Therefore, it is likely that SD cards are within scope of the California law.
I also asked the following questions:
1. Is UEFI considered an embedded operating system, the answer was NO. It is a firmware layer between the hardware and an operating system.
2. Are there any embedded systems that used UEFI? The answer was YES, there are many embedded systems that use UEFI particularly on ARM based devices.
3. Is an embedded system that uses UEFI considered an operating system, the answer was YES.
4. Is the intel Management Engine an operating system? NO, it is a specialized monitoring system but it does incorporate the
MINIX3 operating system within it.
5. Is Docker or Podman an operating system? NO.
6. Are Docker or OCI containers within scope of California Age Assurance? NO, containers are specialized applications.
7. Can
QNX be embedded in a UEFI partition? YES
8. Can FreeBSD be embedded in a UEFI partition? YES with a specially designed boot loader.
9. Are Game Consoles like the PlayStation within scope of California Age Assurance? NO, they are specialized devices, not general purpose computing devices.
So from these answers, my opinion is that a FreeBSD system that is installed as an 'embedded' operating system specifically to run Podman is NOT within the scope of the California Age Assurance law as it is no longer a general purpose computing device. If it is, then so will every intel CPU containing the intel Management Engine and every SD card as they also contain an operating system for a specific task and are also general purpose computing devices.
The distinction between a specialized embedded operating system and a general purpose operation system would likely have to be thrashed out in court. However, using the intel Management Engine, SD Cards and high value devices like ZF Automatic Transmissions (a mobile computer running QNX) as technical shields, may help all other specialized operating systems avoid age assurance compliance.
If a Game Console that uses FreeBSD code is a specialized device, then surely specialized software distributions of FreeBSD can be created to make specialized software development workstations, video editing workstations, portable web browsing and email 'kiosk' devices etc.
Many specialized automated and semi-automated industrial machine tools include general purpose motherboards and SOCs within them. If installing a specialized operating system distribution is considered unsufficient to qualify as being not in scope for age assurance, then all of these machines will be in scope.