Creating a patch to a rom with a fan translation isn't piracy, unless the rom itself is also being distributed for free (or being sold without permission by the owner of the rom).
Taking a rom (with or without fan translation), putting it into a reproduction cart, and selling it without the permission of the creators of the original rom is piracy, though.
To use the analogy of Frozen in Burmese... if someone records a replacement audio track for Frozen, in Burmese, with the idea being that it gets played simultaneously with the video of Frozen (which would have the sound muted), and the audio is entirely reproduced rather than using the original audio, then it wouldn't be piracy. It becomes piracy when they distribute copies of Frozen with the replacement audio without permission from Disney.
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