[MrForbes]

If there is an armature that moves in response to the electromagnet being energized, it's probably a solenoid and illegal. If nothing moves as a result of the electromagnet being energized, it's probably just an electromagnet and legal.

We still haven't seen pictures of the device in question, so it's pretty hard to say.

An electromagnetic clutch used in an automotive air conditioning compressor has a part that moves as a result of energizing the electromagnet, so it's probably a solenoid.

If there is some other type of electromagnetic clutch, I'd like to see it.