i think ‘user replaceable’ should involve no tools, and a minimum of time. if step one involves removing eight tiny screws, and it only gets more cumbersome from there, i don’t think it counts.
The currebt rule says “No propritary tools” which seems reasonable when you add in that glueing in is considered “non-replacable” too. The GBA SP needed a single screw to hold in it’s battery and nothing else. Plus with proper threading, screws last much longer than plastic clips.