No, they were not incorrect. By recent code changes, all outlets in the garage must be GFCI. Many refrigerators will trip GFCI outlets. One solution is to replace the GFCI outlet with a non-GFCI simplex outlet after you have the dedicated line run if it is to be used for a refrigerator exclusively. Our house does have a dedicated 20 amp line to a non-GFCI outlet in the garage because it was built before the code change. The dedicated 20 amp line to the kitchen for our refrigerator is connected to a 20 amp simplex non-GFCI outlet.
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Originally Posted by Woodbear
I received 3 quotes for adding a dedicated outlet receptacle in the garage for our freezer and refridgerator.........all companies said ONLY GFI outlets could be installed. Were all 3 incorrect, maybe  
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