This is clearly a sandwich. The confusion comes from how absurdly sub-optimal its construction is.

Salad is only nachos if it contains croutons, won ton strips, or some other form of free-floating non-structural starch.

So to defeat facial recognition all I need is a Flock of Seagulls haircut?

Live in a climate controlled building. Or just die, probably.

It probably will and will depend on whether or not it makes financial sense for the company to invest in doing things like making software that they have to write, test, and deploy, possibly in multiple versions for multiple regions. The short answer is probably not and so any changes made too confirm to European law will by default also be the case in the US.