In section #5.5 of Java Persistence API 1.0 PFD spec (JSR 220), it is mentioned
that container managed entity manager must be of type JTA.
In table EE.6-1 of Java EE 5 platform PFD spec, it is mentioned that support for
JTA is not required in application client container in Java EE 5 platform.
These two statements automatically imply that an app client can not use
"container managed entity manager".
Please also note that a container managed entity manager is obtained by two ways:
1) using dependency injection: This can be done using either @PersistenceContext
or <persistence-context-ref/> in XML DD.
2) using EntityManagerFactory.getEntityManager().
Verifier should report error for either of these use cases.