Of course they would be. OP said they wrote their own browser. The app store specifically disallows this. You must use the Safari render engine.
The OP said - headless browser, I.e: network and parsing the Dom, but not rendering.
Perfectly allowed. Please stop saying otherwise.
Although I have been thinking about making a JIT. Building on for x86 is easy enough, but then it is useless for ARM. I would not want to build two JITs. Or four with 32/64-bits.
This is a jawbreaker of hyperbole around a chewy gum center of truth.