But an "Emulated" EEPROM is still an EEPROM.
I fail to comprehend how they can specify it has to be an actual EEPROM chip. There is no justification to this. What's inside a discrete EEPROM is not known, it could be a 8051 with a block of Flash. Who knows, and who cares. So in that case, is that an "Emulated" EEPROM? Its not specified HOW the EEPROM does what it does, what is only specified is the pinout and the protocol, re-write life, etc. If you have a device that faithfully implements the 24cXX EEPROM protocol, then it is a serial EEPROM as far as the Raspberry PI is concerned and that's as far as it should go.
Its also an unreasonable technical impediment. An Intelligent Hat has no way to re-write an external EEPROM device when its "configuration" changes, but an Emulated EEPROM does not have this limitation and can, in theory, faithfully reflect the hardware configuration of said "Hat". Which better meets the intention of the EEPROM specification than a discrete EEPROM ever can.