[totaa]

surely openvpn being pre-installed on most routers means it's provided to an significant portion?

[ZiiS]

It is the server that you connect to that is covered by this amendment; they don't care how you connect.

[embedding-shape]

Sure, but openvpn itself doesn't become a "service" just because of that.

[afiori]

i don't think so, it is not provided as a service. if you provide vpn service people can connect to from their router then you need to do age verification before giving them a key/password to connect to the server