However, as at least some of the devices users will be Windows users, it does tend to limit the FS choices to FAT, exFAT or NTFS if the user expects to treat the card as removable storage to transfer files, like in a digital camera, so the issue is pretty much moot. Unless MS are still charging royalties on FAT and the device manufacturer wants to avoid those.
These days with people mainly using their phones, and the transfer of files being done over the air, allows device manufacturers more freedom with their SD card FS choice.