It won’t apply to GrapheneOS. It only applies to certified OSes and GrapheneOS is not certified because it doesn’t license Google Mobile Services. It doesn’t bundle it and it’s also not part of AOSP so that GrapheneOS is built on AOSP doesn’t matter.
Graphene pulls their updates from Android. Not sure if they’re capable of removing this requirement
It won’t apply to GrapheneOS. It only applies to certified OSes and GrapheneOS is not certified because it doesn’t license Google Mobile Services. It doesn’t bundle it and it’s also not part of AOSP so that GrapheneOS is built on AOSP doesn’t matter.