It still is! If you try and boot a kernel with nothing in /dev, you won't get most of the kernel boot messages since /dev/console doesn't exist. You need a basic set of device nodes in /dev before udev is started.

If you're going to rsync a system to new hardware and exclude /dev /proc /sys, it's better to setup a new mount of your / to a different directory and sync off that, so you get the underlying stuff without the cruft.