Yes, indeed. Because of this additional function it is not in scope of Regulation (EU) 107/2009, but it is in scope of 1275/2008 and has to comply with its provisions (as complex set top boxes also have to).
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.