Question came up in class. whether a recessed fixture in the shower stall or above the tub needs to be GFCI protected. my comment was "there is no NEC requirement, unless the instruction that came with the fixture require GFCI protection"
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.
Have you guys seen the newer "Open"style of recess lights for bath shower ares? It is like a regular recess can, and there is no glass over it. The bulb inside is like an outdoor flood bulb with a gasket. I didn't like the looks of it, but it was UL listed and labeled for the application.
I don't remember the specifics about the light. It was several years ago that I saw it. I believe it was a Juno light fixture though. The EC gave me the specs which I stapled to the permit for reference. I haven't seen them since that one time. Maybe the yanked their UL listing.