If there is any field wiring then yes. If the entire thing is a listed assembly then maybe not, or at any rate you arguably just have to follow the instructions to be compliant.
If it were a portable system that you plugged a phone into to recharge then no. If it were a 2kW 12V system installed on and wired into a house then yes. The NEC has no minimum voltage or exclusion for DC. It all depends on how it is used.