I wasn't sure.
It has little to do with instructions. It has a lot to do with the actual marking on the device. The NEC and UL standards require the words LINE and/or LOAD.
GE might make a breaker without the specific markings, Trane may mount this breaker in a roof top unit with the instructions to come in the bottom. Eaton might make a breaker marked with Line on top, Trane would not be allowed to bottom feed that breaker regardless what their instructions said.
Gotcha. It's getting clearer now. A while ago there was a discussion if the installation instructions and drawings, illustrations are part of the UL approval process , thus required to be followed for the device to maintain its approval. In other words, if one do not follow the installation instructions of the approved product, the UL labeling would be null and void. I was thinking of this, and not the device being actually labeled with Line and Load, which makes it even more direct.
You raised an additional area of potential problem, in which case XYZ Company would install the breaker in an assembled unit in violation of the individual device's listing. So what happens if the entire, assembled unit is UL listed?