I think 90% chance of apple going for the EU-Specific model just like they did for Digital markets act, 10 chance of screws, 0% chance of actually popping the back cover off with bare hands.

For Samsung, 50% chance EU-Specific models 40% chance screws, 10% chance back cover tool-less removal. (Edit: typo)

As for other smaller manufacturers, probably just 50%/50% either screws or tool-less back cover removal.