PIN code throttling can’t be implemented properly if hardware doesn’t support it. This is the very purpose of the secure element.

It has its own CPU, storage, random number generator and realtime clock. Once a secret (encryption key) is generated inside of it, it can’t get unlocked until this very tiny chip allows it. And the chip uses different kind of protections (in case of weak pins — the most prominent one is throttling using its built-in RTC clock).

If there’s no secure element, then attacker can just extract the memory chip and easily brute force the encrypted key on the much more powerful (and not throttled by RTC) hardware.

And since the PIN codes are so weak, even the strongest key derivation functions won’t help against such bruteforce.