It looks like it enters a 60Hz quasi-DC dimming mode above 10%, which still flickers and can cause issues but not with the use of PWM.
I'm trying to make sense of the screenshots they had on the site. The top one shows very little modulation, which is a great sign- but I wonder what brightness level that was- are we to assume that is anything above 10%? And the bottom one with much more modulation is a brightness setting below 10%?
And could you expand on what you mentioned- if it doesn't use PWM, but there is still flicker above 10%- I'm a bit of a dummy with this, but what would that mean for people who are maybe just slightly or mildly sensitive? And would this overall be a good thing vs. using PWM for dimming? Just trying to wrap my brain around what this means- because as you said, certainly there is still flicker- even at 90% brightness on the 13 Mini I tested at the store, it flickered just as much as my 12 mini does when taking a slow-mo video of the display.
EDIT:
I as because I've had my 12 Mini since launch... the first couple of weeks caused me just a bit of dry, gritty eyes as I adjusted to the display.
However, I adjusted to the 12 Mini and it's very easy on my eyes now- I found that 90% brightness and then a reduce whitepoint of 95 got me to a place to where the flicker didn't bother me in the slightest, and it wasn't too bright for my eyes that are rather light sensitive.
But when I played around with a 13 Mini for a while, something was different- no headaches, but just a bit of that gritty, piercing feeling in the eyes, no matter what I did with brightness/reduce whitepoint. Not quite sure why that would be, assuming it can't have worse pwm flicker than the 12 mini- and reading the writeup today on the regular 13, I would almost think that the 13 mini is the same- which should be easier on the eyes.