Yes. This is what is said in the Code, in your words. . . but look at the phrasing of 250.64(D)(1)(3) especially the highlighted green:
As written the busbar does not have to be listed. But the connection to the busbar does have to be listed. In the photo in this thread, the green #6 Grounding Electrode Conductor is connected to the LUG (which is listed). The lug, in turn is connected to the busbar.
It is the second connection, the connection of the listed lug to the busbar that is, in my opinion, included in 250.64(D)(1)(3) as a "Connections to an . . . busbar . . . "
Clearly, for an effective low impedance electrical path to be accomplished, the LUG must be connected to the "busbar" (a busbar constructed as physically described in 250.64(D)(1)(3)) and I can't see that the language allows an unlisted mechanical bolt and nut, screw or other fastener grabbed off the truck to do the "connection to an . . . busbar . . ."
The connection to the busbar must be by a "listed connector."
If the lug was supplied with a fastener that was part of the listing of the lug, you know, like the screws that come with an EGC terminal strip, or the MBJ screw that is included with a panel suitable as Service Equipment, then I believe the NEC rule is satisfied. But the photo in this thread shows generic listed lugs held with generic unlisted fasteners.
I disagree.
To me, the bolt and nut have very little to do with the actual connection of the lug to the bar itself.
The bolt probably doesn't even contact the inside diameter of the drilled hole in the bar.
It's doing nothing more than keeping pressure held between the listed lug to the listed buss bar.
If you crimp on a listed 2 hole crimp lug, (which don't come with a bolt and nut), which is what most ground bar hole patterns are drilled for, how would you ever connect the crimp lug to the bussbar without using standard bolts and nuts?
The buss bar doesn't come with nuts and bolts and neither does the crimp lug.
Every buss bar I've ever installed comes with holes drilled in it and that's it.
if there is an option for "listed" nuts and bolts I've never been made aware of it.
Unless they could prove that the bolts and nuts that they send separately were required to maintain the listing of the lug I don't see how they would be any different than nuts and bolt you'd buy anywhere else.
They may have a guide on the size, length, and torque setting possibly that are needed.
Even If the bolts and nuts to bolt the crimp lug onto the bussbar came as an option in a separate bag that you have to install yourself, I don't see how that could be considered to be part of the listed items for the lug or the bussbar seeing as how they aren't bolted to the bar or come with the lug to begin with.
I may be wrong, but, to me it would be the same type of normal nuts and bolts you could buy anywhere.
JAP>