Avoiding GFCI for my fridge

Question

I'm wrapping up a whole kitchen remodel, including redoing most of the kitchen electrical. Today we installed the fridge in its new location and plugged it into its new outlet, but 15 minutes later it started tripping the GFCI (and again another 15 min later, etc..). Oh boy..

The fridge is on a circuit that first serves some kitchen countertop outlets upstream of the fridge. The first of those outlets has a GFCI with the breaker side connected to "line" and the rest of the circuit downstream connected to the "load" side. This is the GFCI that keeps tripping. It's also a relatively new GFCI so I doubt it's faulty.

I realized now that it's not uncommon for fridges to trip GFCIs, but it's too late for me to run another circuit to the fridge (or make the fridge earlier on the circuit, or tap into another non-GFCI circuit, etc..) without having to do a ton of work ripping open walls and removing cabinets. I also realize that I can't pass the final trim inspection without having the kitchen outlets be GFCI'd.

My plan is to change the first GFCI on that circuit so that it only covers that outlet itself but nothing downstream. That is, leave the "load" side empty, and just do a regular splice in the box to energize the rest of the circuit. Then add another GFCI to the next kitchen counter outlet and do the same thing there. That way, the fridge is not GFCI protected but both countertop outlets are. If there are other outlets downstream of the fridge, I'll add a GFCI to the first of those and connect the rest of the circuit to its load terminals. In summary, I'd GFCI all the individual outlets rather than the rest of the downstream circuit.

This will cost me another $20-50 for additional GFCIs, but at least I don't have to rip walls open and reroute circuits.

My questions are:

1. Is this a good plan in general? Anything major, I'm missing? Any easier way to solve this problem?

2. Is it a code violation for the fridge outlet to not be GFCI'd, given it's within 6' of a sink? Does that really matter since the fridge outlet is actually not accessible during normal use (the outlet is entirely covered by the fridge and is inaccessible without first taking out the fridge)? Any chance an inspector would call this out?

Answer 1

Kitchen outlets are only required to be GFCI when they serve the countertop

NEC 210.8(A) point 6 only requires GFCI protection for receptacles that serve the kitchen countertops:

(6) Kitchens — where the receptacles are installed to serve the countertop surfaces

So, you're fine Code-wise with not providing GFCI to the fridge.