Wince's "ROM File System" is generated with Romimage. Organize all execution files (EXE, DLL) code in nk.bin to "flat space" (redefine DLL and EXE running address make it no overlap), in accordance with the runtime format, etc. (this saves load positioning Process), other information of the file (such as file name, start address, length, etc.) organized in a specific paragraph for finding. Observing the output of Romimage can be seen such as: E32, O32, and so on.
CE's kernel identifies the structure of the ROM File System, so you can find and load the DLL, EXE, without the help of FileSys.exe.
The file system is not provided as part of the CE kernel (unlike Linux, the kernel provides the file system service), but is provided by FileSys.exe. So if the CE kernel does not support ROMFS, there is no way to load FileSys.exe, and there is no way to provide the service of the file system.