Agree.
Although EMC testing it not in a case is Shirley very silly? They will then have to get it redone when they do a cased version. I didn't think invaded goods had to be EMC tested, although I'm still learning about EMC myself so probably a lot I don't know.
It has nothing to do with whether it's cased, the requirement for CE marking is the responsibility of the end manufacturer. There aren't technically any exceptions, but development boards generally tend to get away without certification because they're not intended for an "end use".
The moment raspberry pi started putting up information on and helping with ports of XBMC, they effectively gave the product a purpose and a different set of non technical users became interested, consequently they sold a lot of units which no doubt will end up sitting behind TVs. Because its a "end product" (they'd have a hard time arguing otherwise) they need compliance to make sure they don't end up in a lot of potentially quite serious trouble. CE is complaint driven, so if somebody did complain about EMI then they'd have a lot of explaining to do as to why they were selling it.
And for what it's worth, if you can make a bare board pass EMC testing, then a cases version should be a mere formality as it should provide more shielding.
Its more silly to redesign, reverify and make new shims for stencils than it is to repeat an EMC test. Having done lots of EMC testing recently, it's far easier, quicker and cheaper to fix the problem early.
When you've got large expensive BGA chips, the last thing you want to do is find that you've just made 10,000 door stops because the fault requires a design change.
We design hardware for integration into equipment for OEMs and we do EMC testing on our bare boards to show potential customers that they're not going to have a problem, we do this because it's a selling point for us, not because we need to or have any obligation to do it.
Harsh lesson for them in world of electronics manufacturing that could have potentially gone very very wrong for them.