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AFAIK it does not apply to embedded SIMs as you cannot remove it and use it for any "normal" phone functions. There is also no phone number associated with it.
I do understand that Kindle is using Vodacom in South Africa (please correct me)
How exactly are you going to RICA it? What cell number are you going to give the guy to RICA it?
Customer: "I want to RICA my kindle device"
Cell shop owner: "OK, what is the Cellular Number?"
Customer: "It doesn't have one."
Cell shop owner: "GTFO and stop wasting my time!"
I'm not so sure about the post saying that you can use any service provider with the Kindle. Outside AT&T in the USA, Amazon only have the 'free interent for life' deal with Vodafone partners (thus Vodacom in SA) -- so if a Kindle manages to access MTN in SA then something is definitely wrong with their system!