I propose to allow a RCD as substitute for SPGFCI 210.8(B)(2).
There is already an existing open standard used all over the world on 120/240 50/60hz, 230V, 230/400V 50/60Hz and even DC systems that accomplishes the same thing as a SPGFCI.
A Residual Current Device (RCD) I would like to propose a code change that such (properly listed and labeled) already manufactured off the shelf products may be used to meet the SPGFCI requirement in the NEC.
UL 943C has not published any open accessible peer reviewed studies demonstrating why a new different standard (20ma) is needed vs the (25ma - 30ma) of an RCD.
This would provide the same protection used world wide and make it easier on industry.
Consider industry that falls under both the NEC and international standards.
This would lower the costs of electrical installations and provide the expanded protection with existing technology that our European partners have used for decades.
Either way manufacturers would probably have to make a residual-current circuit breaker with overcurrent protection (rcbo) for US residential panels, however its a technology they already use widely and the costs to consumers would be much less.
The requirement could even be expanded beyond the 15 and 20 amperage rating.