

I’m saying there’s no reasonable interpretation of this provision where a dev would be seen as supplying to Google by distributing an app that runs on Android without using Google’s store. Given the broader context of the CRA, it should be more clear; the CRA is about supply chains, and generally imposes obligations on entities acting as links in the supply chain. Google can’t sell apps if it doesn’t know where they came from.
The fact that Google plans not to forbid installation of unsigned apps via ADB would be a huge loophole if the intent was to force OS vendors to control all app distribution for those operating systems.
Apps definitely qualify as products with digital elements. The term that determines whether Google has obligations is this scenario is ‘economic operator’ Here’s the definition for that:
When Google distributes apps via the Play Store, it is very obviously the distributor, which is defined:
If someone else distributes apps using other infrastructure that happen to run on an OS that Google made, Google is not the distributor and does not incur any obligations that apply to distributors. (For completeness, Google is obviously not the manufacturer, authorised representative, or importer either.)