I do not know any specifics about the things vendors have to sign, the security review event or the compliance suite, but yes it allows re-identification unless you reset and setup the device anew based on the device's primary use case (usually cryptocoins).
Long story told short. When setting up eg a Ledger you get a backup phrase which gets calculated into keys for all sorts of things as a backup if the device breaks down, which can be imported into a new device to restore most things.
These keys include the master secret for non-resident keys
So to reset you would have to go into the settings on the device, reset it and either import a different backup phrase or create a new one in the setup process.
With the way this device is designed to act I do not consider this particularly of an issue in itself, but it does go against the "word of the law", one could say.
Especially as earlier revisions were a lot more ambiguous about the command (but still never stated anything about a potential technical contradiction between a device's individual functionalities.
The way this is designed it could not even go with what is needed for an authenticator reset if the device wanted to, due to a new device with the same backup phrase not being aware that such an event even happened, unless it unless it decpupled the fido master key stuff from the backup, which I would not consider the greatest solution either.
I have not tested any devices besides the ledger Nano S for this, as it's the only i have that i am aware to be listed in the certified products list.
All devices i am aware of with this specific technical setup tho do have a display and are generally updateable, so especially for certified ones, the devices could be updated to act by
1) throwing not allowed or operation denied
2) at the same time show something about the reset on the display
While at the same time opening up something for eg ctap2.3 for such devices to respond with a more proper error code and eg an info link to eg reset instructions for the whole device.