You are probably right - panel instructions likely still didn't allow it.It was added to the NEC in 2002 but was not permitted for decades before that by the listing of the panel. It was only added to the NEC to make people more aware of the requirement.
You are probably right - panel instructions likely still didn't allow it.
Seems if it was a listing issue they should have added a FPN that mentions/references the listing requirement instead of adding an actual code requirement. But what do I know about writing code?If you go back to the 2002 ROP you see that they added the wording directly into the NEC because most installers didn't know about the listing issue.