So the measurement is to the receptacle for a refrigerator, but to the cooktop from a sink. Nice consistency.
No. In the 2020 code the measurement is from the sink to the receptacle in 210.8(A) and 8(B).
In the 2023 code the requirement is that all receptacles in a dwelling unit kitchen have GFCI protection. The rule is still for receptacles within 6' from the sink for sinks not in a kitchen.
However the rule 210.8(D) for specific appliances has been expanded to include additional appliances. This rule requires that the
outlet that supplies any the listed appliances must have GFCI protection and that applies to both dwelling and non-dwelling occupancies. List items (8) through (12) are new for the 2023 code. The previous code just referenced 422.5(A) that only includes the first seven list items. Note that this rule does not say receptacle....it says outlet.
The list is:
1) Automotive vacuum machines
(2) Drinking water coolers and bottle fill stations
(3) High-pressure spray washing machines
(4) Tire inflation machines
(5) Vending machines
(6) Sump pumps
(7) Dishwashers
(8) Electric ranges
(9) Wall-mounted ovens
(10) Counter-mounted cooking units
(11) Clothes dryers
(12) Microwave ovens