The DW is attached (by screws to the countertop) that is why it is not code to put a receptacle behind it. Stove and Refrig are generally designed to be moveable for cleaning. If you have a built in cooktop, or sub zero type refrig, both attached...no receptacle allowed behind them either. Exception: portable DW on wheels. I like the plug and receptacle for the DW, seems the other trades damage the dw romex whip.
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