The Installer need not be implemented as an applet on the card. The requirement is only that the Installer functionality be SELECTable. The corollary to this requirement is that Installer component shall not be able to be invoked on a logical channel on which a non-Installer applet is an active applet instance nor when no applet is active.

Obviously, a Java Card RE implementer could choose to implement the Installer as an applet. If so, then the Installer might be coded to extend the Applet class and respond to invocations of the select, process, and deselect methods; and, if necessary, the methods of the javacard.framework.MultiSelectable interface.

But a Java Card RE implementer could also implement the Installer in other ways, as long as it provides the SELECTable behavior to the outside world. In this case, the Java Card RE implementer has the freedom to provide some other mechanism by which APDUs are delivered to the Installer code module.