Although you may be right about why they did it, I feel like imagery of gambling is not meant to be ‘something that is in any way related to something that happens to be gambling’, it’s when gambling is shown but you’re not the one gambling. If someone in game is gambling that’s imagery, if a game uses cards for something that is not gambling it’s not imagery.
Which is why PEGI didn’t say it was literally gambling, they said it was imagery of gambling.
Although you may be right about why they did it, I feel like imagery of gambling is not meant to be ‘something that is in any way related to something that happens to be gambling’, it’s when gambling is shown but you’re not the one gambling. If someone in game is gambling that’s imagery, if a game uses cards for something that is not gambling it’s not imagery.