Never been a manufacturing requirement to meet listing, strictly a code and enforcement issue locally as to what constitutes the system in it's entirety and to what extent would need to be FPL rated cabling....no different than some municipalities not allowing plug in system transformers and requiring hardwired units.
From a liability standpoint, if the only notification appliance is a siren/speaker attached to the system and not integral to the detector(s) themselves, would it be considered prudent...sure, but again, this starts getting into some grey areas again, because there is no specific requirement for the detectors to have integral sounders either, it's more of a what the AHJ would prefer vs. what is or was SOP. The only requirement is a dB level at pillow height or above ambient.
That said, to what extent the ancillary peripherals (keypads, siren/speakers, transformer wiring, data wiring between components, etc.) would benefit from the FPL cabling should be investigated and considered.