It's just strange to release an empty cartridge with 13GB required download, unless it's for collection purpose but that would be money loss for the publisher to produce empty cartridge. they could just release the game only on eshop.
So, based on that updated comment, that's fine if the game data is on the cartridge.
Thought, it's stated on the box "internet required", who made the box design? :s
Maybe the game could still require 13GB of data to be installed, but direct cartridge access should be faster than copying the game to the console, right? and it wouldn't require internet, unless it's used for something else.