I recently learned that there is a business doing exactly that:
I don't think it's high volume, I think this is done by some of the microg folks.
But OEMs probably do everything in their power to make this business model unviable or at least not scale.
It is one of many projects that make alternative, AOSP-based operating systems (e.g. GrapheneOS, LineageOS, /e/OS), and some of them sell devices for an additional source of income (e.g. Murena who develop /e/OS also does this).