Earlier quoted context omitted.
Apple says you must be physically located in an EU country to be eligible, as determined by your device, so presumably they are checking GPS and/or cellular location data rather than just IP geolocation.
Even if on-device location is disabled?
I recently spent a bit of time trying to bypass the location check (out of curiosity) and they have it pretty locked down.
The key is they require WiFi to be on so they can get around GPS spoofing.
I had even attempted re-creating all the SSIDs and other networks nearby my spoofed location but the existing networks near my real location were reducing the confidence and still getting me flagged.
One thing I learned during this was how complicit browser manufactures are in providing this information. There is no way to enable location services but disable WiFi triangulation in any mainstream browser. If you disable location permissions websites can just outright block you.
End solution was just a remote KVM setup but not exactly what I wanted.