I still think you're missing it. It's not immaterial at all. ALL EVSE's must have GFCI built into them--no exception. That applies to both plug-in or hardwired. That is not the issue. It's not about what's built-into the EVSE.Point taken and fair enough - although in practice I'm guessing the difference is immaterial as I don't imagine there's a hard-wired EVSE on the market without built-in GFCI.
There is a very specific difference in practice that is not immaterial, which is that if you are getting a hard wired one, you DO NOT have to use a GFCI breaker, but if you are installing a receptacle for a plug-in device, then you DO have to use a GFCI breaker.