I didn't think it was so much about the technical challenges but the licence and IP issues?
Nvidia's been doing fine so far. I know that distributions theoretically support them, but everyone I know uses envy-ng for some reason (new hardware support, problems with resolution, etc.) So even if the distribution is lagging behind, a good update script that is needed only during a system upgrade isn't that ugly... Especially if ZFS will be used by proper admins that will choose it based on what they really need.