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HCFX BOTB 2012 - Official Rules List and Guidelines
I think because it's an accessory for another pedal, and not a specific pedal, in and of itself. A tuner pedal does something on its own. An expression pedal is worthless without it's mate.
Man some of you guys are really adament about your tuners counting as pedals. I don't get it. It's like a mandatory piece of gear that's expected and won't really be judged. Why count it towards the total and why only sometimes? If it's a pedal it should count if it's in a side chain too.