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Are there UL-listed electric baseboard heaters that do permit being installed below outlets? The FPN in 210.52:

Informational Note: Listed baseboard heaters include instructions that may not permit their installation below receptacle outlets.

uses the word 'may', which makes me wonder if some baseboard heaters can legitimately be installed under a receptacle and others cannot without violating the listing, or if the FPN's wording is not strong enough and could do with revising for the next Code cycle?

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The short answer is yes, some might be OK... the FPNs are separate from the actual code; they aren't enforceable. However, if the installation instructions prohibit installation below a receptacle, you're going to be considered in violation. I'd be surprised if any of these types of heaters allowed it...

You can always get one of these.

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