I think the issue is worse than not implementing USB-PD, it won't charge at all when plugged into a usb-c port, thus not complying with the usb-c spec while having a usb-c port. I'm no lawyer but the author says it's illegal in some jurisdictions.

In your declaration of conformity you have to list which standards you conform to, and IEC 62680-1-3 would be one of them. I suppose if you found to be lying on your declaration there would be consequences.