(1) If it is cord and plug connected, then yes per 2020 NEC 625.54. If it is hard-wired and installed outdoors at a dwelling unit on a branch circuit rated 50A or less, then yes per 2020 NEC 210.8(F). [I guess if you installed an isolation transformer at the dwelling unit to create a 2-wire 240V or 208V SDS, then you could supply an outdoor EVSE with the resulting circuit and not need GFCI protection.]
(2) Manufacturer's instructions never overrule the NEC. If the NEC requires X and the instructions say "do not do X" then the instructions are telling you not to install the equipment in jurisdictions subject to the NEC.
Cheers, Wayne