...which would require a valid SIM. So just don't add one. If the device comes with a pre-inserted/hardwired/virtual SIM, well... several countries in the world require KYC-style registration of the SIM owner before networks are allowed to activate the SIM, so there'd still be an opt-out path for the user in such countries.
eta: My point being: Now you're in a twisty little maze full of corner cases, all different. Not the sort of thing much loved by Amazon (or any of the GRAFT).
Not in the IoT world. The 'owner' of the Sim, the company that sells the device, would have a deal with one or more network providers to allow access, and take care of facilitating data retention and identification regulation.
eta: My point being: Now you're in a twisty little maze full of corner cases, all different. Not the sort of thing much loved by Amazon (or any of the GRAFT).