The NEC is a MINIMUM standard! I always put the washer on a Ground fault circuit (a recep). 8 bucks ain't gonna make or break you on any job.
Besides, you almost always get extras on houses so you can easily make up for those few dollars.
I usually go above and beyond code requirements in houses anyway (when I'm doing them for individuals NOT builders!).

I can't wait 'til NEMA comes out with Arc Fault receptacles...