Refrigerator outlet

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If the receptacles is within 6 feet of the sink then it needs gfci. I am assuming residential because commercially all kitchen receptacles need gfci.
 
NEC 2011

All receptacles that serve the kitchen counter need to have GFCI protection.

If the fridge is being plugged into a counter serving receptacle then it will be protected by a GFCI.

If the receptacle is behind the fridge or in the nook area and still within 6' of the sink then GFCI protection is NOT required. IMO.

If the fridge is in a wet bar sink area then all receptacles within 6' of the wet bar sink need to have GFCI protection.
 
Now come on. You wouldn't want some child to receive a shock if they accidentally dropped the fridge into a sink full of water, would you? :happyno:
 
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