The code only prohibits having lighting outlets on the counter top
receptacle circuits and although it permits the refrigerator to be
supplied from such a circuit it does not require that. So a receptacle
placed behind a refrigerator so as to be inaccessible for counter top
use could be supplied from a lighting circuit.
--


Right... The refrigerator outlet in most dwellings is on a different
circuit than the 2 required 20A countertop appliance outlets. These
outlets are suppose to be for coffee pots, microwave ovens, broillers,
blenders, can openers, etc. Two of them are needed because most of
these kitchen appliances consume lots of power.

Also note that the fridge outlet is one of the few exceptions that
should not be on a GFCI outlet, lest it nuisance trip while you are
out of town and spoil your food. The NEC recognizes this, even though
the prevailing sentiment will be to require GFCI's on just about all
outlet circuits in future codes.

Beachcomber