I do not follow. Even if it is an appliance, how does this alleviate the need for a disconnect? I think that it is good practice even if not required because it is the HVAC guy that has to service them.
I thought about this a little more and these are installed on the load side of a switch or one kind or another. Often within sight sometimes with a manual test switch for the initiation device. Does this change anything even though the switch would likely be remotely controlled?
This is an excerpt from the June 2006 Washington State Electrical Currents newsletter (Vol. 9 No. 6) written by Ron Fuller, chief electrical inspector
"Do HVAC Damper Actuators Need Motor Disconnecting Means Per NEC Article 430?
No, an actuator is considered a component of the damper assembly and is not subject to the
disconnect requirements of NEC 430.101. Though often called by other names such as damper motors,
damper operators, or motor packs, damper actuator is the appropriate term. A damper actuator is not a motor subject to NEC Article 430."
While I can't really come up with any specific code that says a disconnect isn't required, I have never been required by any AHJ to install one and I am a temperature controls/BAS installer.