So why continue with it as selling pre-burned "ROM" chips? Make a board that carries yor original 3.1 ROM and a flash chip, like a kick switcher. When writing to the ROM addresses, obviously you're only able to write tot eh flash, so do that, even if you booted from the original 3.1 ROM.
Well, this does exist, mfilos showed me such a project/kit on Aminet yesterday. Thing to do, is build & sell me a drop-in device that lets this happen relatively easily, and use something like Luciferin FlashRom software.
Why no one bothered to build and sell such a device is strange, to me. But I am naive about hardware. Would add that this would clearly have nothing to do with copyright issues.