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Japan’s national library says it won’t be preserving Switch 2 Game-Key Cards | VGC
(www.videogameschronicle.com)
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Makes perfect sense since there's not really any media on them, not to mention being a massive waste of public funding.
In Belgium publishers are obligated to send a single copy to the national library, so in that case the only public funding that is wasted is the extra storage space, which would be rather minimal. I don't know if Japan has similar rules, but I wouldn't call it a "massive" waste compared to some other places where public money is spent.
I studied some courses on archival, so I am probably biased. I think preservation is important, and even in this case I would prefer for them to be archived too, as the box and box art are also part of the piece and of cultural significance.
I also can't say I know for sure, but given how grubby Nintendo is and the crap they get away with, it wouldn't even surprise me if they're somehow an exception to such a rule.