So it appears there is going to be an increase in GFCI breakers in panels.
And yes, you can legally connect dishwashers and garbage disposals to non-GFCI outlets as long as it doesn't go against the laws/ordinances of the AHJ. But as the NEC has established new requirements, doing so isn't "best practice".
Sometimes "code" needs to be taken with a grain of salt in lieu of "best practices" and in that respect,
@MicEd69 you nailed it. Code is merely the barest minimum legal requirement and often isn't comprehensive enough. A smart electrician or plumber or any other contractor will go above and beyond code when best practices (not to mention logic) make sense.
"Code" in this case has to do with the LOCATION of an outlet, and has
ABSOLUTELY NOTHING to do with the
use of that outlet, or even if the outlet is used at all! If an outlet is near water, (or outside or in a garage) it SHOULD be GFCI protected. That's best practices.
If that outlet under the sink is GFCI protected (from upstream or a breaker), it should be labeled as such, though this is rarely ever done. Personally, I'd rather have my undersink outlets protected upstream with GFCI either by an outlet before it, or a panel breaker. If the GFCI protection at that point is ONLY from a GFCI outlet there, if tripped, only the outlet itself has the hot cut off. The power to the outlet itself is still hot and live in the box. If the GFCI protection is at the breaker or upstream, then the power is cut upstream, and no power remains in the outlet or box. Big difference.
My prior dishwasher (GE Cafe) that came with my home was hard wired. The replacement dishwasher (Bosch 800) only came with a plug. So I had to install an outlet in the cabinet...and yes I used a GFCI outlet. Local code or practice--I don't know which or why--has power to the disposal/dishwasher sharing a neutral with a three-wire feed, and two 15A breakers in the panel joined. This 3-wire meets in a J-box under the sink/dishwasher area in the crawl space, where it separates to two 2-wire cables. One now feeds a GFCI outlet on the right side that serves the air switch for the disposal, and the other on the left side is where the dishwasher plugs in. I installed BOTH of these outlets, albeit at different times. Yes, two GFCIs under my sink. In my case, really the best solution would be to change the breaker(s) to GFCI. They are dedicated only to these undersink uses.
Anybody can do pretty much whatever they want. I install a lot of disposals and faucets has a handyman, and I rarely see an under sink cabinet that has NOT seen water damage from a leak. So it only makes sense that in these areas that get wet, you ensure GFCI protection.