Reclined seats for take off and landing
In normal cabin seats, the reason not to recline them for takeoff &amp; landing is so the reclined seat won't impede egress for passengers in the row behind yours.  If the seats in question on VA wouldn't do that (ample space between rows, perhaps), then the usual driver for requiring seats to be fully upright is gone.

Presumably whatever "certification" they referred to considered the ability to get out of one's own seat in case of an evacuation.