I think this is a brand new tactic on the part of VeriSign, to categorize it as a "non-registry service".
That seems to escalate things to a new level, in that it seems to be an admission of abusing their monopoly in the Registry for the provision of a NON-REGISTRY SERVICE.
It had been my understanding that previously their position would have been that it would have been categorized as a Registry service, but one that didn't need approval due to it being "free" (i.e. needs no contract amendment). However, giving advantage for the provision of a non-registry service seems to be MUCH WORSE. Suppose that NON-REGISTRY SERVICE was a REGISTRAR SERVICE, for example, and VeriSign abused its monopoly to advantage one of their partners in that space? Can someone say "WLS"?
Clearly, VeriSign's abusive and monopolistic business practises need to be examined at the highest levels of government and by regulators.