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Google it.....loads of BMWs are sold as BMW Approved Used without FSH and lots of discussions like this thread on BWM forums..........they might say otherwise but they don't stick to it. So not really any difference to Mercedes on that front.
It seems that the difference is that BMW say that their approved used cars will all have FSH, even if BMW dealers don't actually adhere to this, while MB do not commit to their approved used cars having FSH, which means that MB dealers are doing nothing wrong by selling cars without FSH as approved used (as long as they don't misdescribe them, obviously).