210.52 (C)(5) requires the receptacles to be readily accessible. It then goes on to exclude receptacles in appliance garages from consideration as the required receptacles.
This section begins with 'receptacles shall be above' .... but then gives conditions for placing them below the counter.
Some might consider receptacles in a drawer to not be "readily accessible." Just concealing them behind, say, a flip-down panel would appear to be allowed by the NEC.
Unlike some of my other threads, this one was not started to focus on the inadequacies of the NEC. Rather, I wanted to focus cabinet designers on the NEC requirements ... so they could incorporate the receptacles into their designs.
I would not be at all surprised if, eventually, factory made cabinet panels come with receptacles already installed, listed for field assembly.
