Apple has come up with a way to update an iPhone still in its packaging, with a system allowing for iOS updates to be applied to unopened smartphones while still in an Apple Store.
Obviously they can’t. They place them on a pad, presumably a wireless charging & communication pad. Literally says in the article:
“The pad wirelessly turns on the iPhone, runs the software update, then turns it off again.”
So they will remove each and every iPhone in the box. Thats kinda hard to do considering the number of iPhones in storage. Probably easier to wait for each iPhone to activate then apply the update.