A few years ago, the testing standards for GFI's was changed. One result of this change was that new GFI's are much more resistant to nuisance tripping than earlier models. They also require a good neutral path, or the GFI will trip.
That said, there IS a conflict within the NEC on the issue. While the section quoted has no exceptions noted, section 110.3(B) also has no exceptions noted where it says 'equipment shall be installed according to instructions.' (slight paraphrase for clarity).
I am looking at the instructions provided by Dacor, a premiun brand of refrigerator. Their sheet states "Your Dacor Built-in refrigerator is equipped with a .... power cord, which must be plugged into a 3-prong grounding type non-GFCI wall receptacle."
So, it seems that it's not a question of whether you violate the NEC; it's a question of which section is violated!
Since the 'law' here is contradictory, I can only fall back on the principle that any ambiguity in a contract be construed against the party that wrote it.
In this case, that would mean that the GFCI rull cannot be enforced against refrigerators in commercial kitchens.
