Mind boggles at the possible legal minefield you could walk into on that one:
Misrepresentation of product / fraud
Labelling laws (at least in the UK)
Use of none FCC authorised equipment and any associated wireless telegraphy (love that term) law
Creating unlawful interference to emergency services
Copyright breach of the FCC logo
Contract law may get thrown in by the OEM
We still have the ‘misuse of electricity’ law in the U.K. that got thrown at early hackers (bad kind) - it’s never been repealed
and I am sure a lawyer would come up with a pile more (international trade agreements spring to mind) over a cup of coffee (that you would be paying for)
Me - paranoid - nope I know they are watching
Of course if you certify the whole unit then it does not matter that part of it is not certified originally but how that works with field replaceable units (IBM FRUs) like this I have no idea... it’s why certifying companies charge so much.