That's like saying the 3DS isn't a video game system because the CTR dev unit is the video game system and the 3DS is the final result with changes locked.It's an asic, purposebuilt. FPGA are the intermediary device that comes before an ASIC device. FPGA is a field-programmable gate-array, whereas this device is purpose-built; Application-specific integrated circuit, while how it does what it does is determined by firmware, instructions etc, what it does is pretty specific to the IC.
It's pretty clearly labeled as an asic.
This sort of thing would be much closer to the type of FPGA we'd see workin' with a 3ds: http://www.maxconsole.com/maxconsole/contents/RKLS00000013519/icon_xl.jpg
as the FPGA, in uses like this, are generally gigantic, maleable prototypes to hone in on the steps you need to take to move forward. The asic is the purposebuilt end-product.
But that was my point, that the chips used in flash carts, by the time they get to the end-user, only have small bits that can be changed.