IANAL, But I think device as-is can likely be sold and marketed perfectly fine. Test-kit and dev-kit stuff is regulated a bit differently under the assumption that it's not going to be in mass use, and also that it's likely going to be used to develop another product that will get the fcc certification.
The link you provided appears to say the opposite about kits:
"Based on the definition above, it looks clear that non-authorized kits that are intended to form a complete product when fully constructed are technically not legally permitted to be sold in the US. That is because if you are marketing and selling a kit to an end user, which the user will then build into a full product, there is no reason to suspect that the normal rules would not apply."
The subassembly rules could work, if they apply, but I don't see how this product fits the definition of a sub-assembly:
"No authorization is required for a peripheral device or a subassembly that is sold to an equipment manufacturer for further fabrication."
In fact, I think it's a stretch to say that any of these test-kit, dev equipment, or subassembly rules apply. This basically strikes me as being marketed as a consumer product -- albeit a product for very tech savvy consumers.
https://emcfastpass.com/fcc-rules-kits-subassemblies/