if E57 is correct and this tub is fed with a "feeder" because the last overcurrent device at the tub (which I disagree with, I think it would be a non-fused disconnect and not an overcurrent device)
E57 is talking about the fact that there is a load center (circuit breakers) built-in to the hot tub control panel, not the disconnect switch that supplies the tub.
My feeling is, that the unit, being listed as an assembly, probably qualifies as an appliance or fixture.. The next question is, how does the UL tag identify it?
Also, does the load center supply additional equipment that is not either part of the tub assembly, or connected to a convienience outlet located on the tub assembly?