The question concerns 'accessible'.
Fortunately, the NEC covers this in Art. 100.
I would not consider the toaster, coffee maker or bread machine that's inside the garage an 'obstacle' any more than the door to a bedroom an obstacle to the panel behind it. if you're going to be that hard-nosed about it, then you won't be able to put anything on the counter directly in front of the receps that serve it. No soap dispensers, no utensil containers, no knife racks, no paper towel dispensers, no cutting boards, no dish-drying racks, no potpourri jars, no serving trays, no silverware racks, ...........
Heck, one might argue that the countertop itself is an obstacle that must be leaned over to access the device.
See the above quote.