The EV charger unit can be simply directly wired utilization equipment no different that your electric stove. Not needing to meet the requirements of a feeder. This unit by including a breaker internally I think would make the circuit wiring between the panel and this device a feeder and need to meet the requirements of a feeder.
A load shedding device in of itself is mearly an automatic switching device that is monitoring frequency change that is a result of loss primary utility power and then turning of the load under specific criteria. And by itself would not need to be installed as a feeder, but by having the breaker integral it changes everything. I've used load shed devices the past that did not have breaker integral to the shedding device. They now have more than enough capacity for an EV charger. These ones also did include signage indicating no serviceable parts inside.
The unit pictured may have the intent to also be the local disconnect and if so would need to be placed in such a way to meet those requirements, and the feeder requirements. I think the OP has a point for the lack of isolation of live conductors in relationship to the internal breaker if the intent likely is for it to be the local disconnect as well as a load shedding device.