It would depend on the extent to which the consumer is a willing participant in the trade offs. It’s unreasonable for every passenger to assess the safety of different airlines in making a decision on who to fly with, but if you’re buying a niche smartphone you’re probably more aware of the trade offs.
Also running a small batch of non-RtR compliant phones is probably going to result in a more expensive device than a mass produced RtR device due to economies of scale, whereas I’d guess it’s much easier for a small airline to undercut competitors by foregoing safety checks, so there’s more adverse incentives in the airline case.