This is the handbook commentary
The last sentence of 410.10(D) clarifies that securely fastened luminaires installed in or on the ceiling or wall are permitted to be located in the bathtub or shower area. Where they are subject to shower spray, the luminaires must be listed for a wet location. Luminaires installed in the tub or shower zone and not subject to shower spray are required to be listed for use in a damp location. GFCI protection is required only where specified in the installation instructions for the luminaire.
The way I read it you can put a jelly jar on the wall in a shower and you still don't need GFCI. Would I do it ... no.