As the law is written, the latest iPhones, for example, would be compliant (battery is replaceable with commercially available tools under the self-repair program), and they are completely waterproof and dustproof. Some manufacturers now use glued seals for their phones and would probably need to change their approach in design, but I think the majority would be okay with minimal changes.

Like others have pointed out, if phones can certify using batteries with 1000 cycles of charge above 80%, they'll also be exempt, so this will likely only affect very cheap models.