Unclear, but a member of the ZFS development team at Apple told me that Giampaolo complained that ZFS would never work on the phone. So the team demonstrated it working on the phone. I know of no obstacles to making it work on the watch other than engineering.
So they still have a team working on ZFS? Could the anonymous "ilovezfs" involved with OpenZFSonOSX and coming from a California IP address be part of this team?