210.8 Informational Note No. 2.  For the purposes of this section, when determining distance from receptacles the distance shall be measured as the shortest path the cord of an appliance connected to the receptacle would follow without piercing a floor, wall, ceiling, or fixed barrier, or passing through a door, doorway, or window.

210.8(A)(7).  Sinks – where receptacles are installed within 1.8 m (6 ft.) from the top inside edge of the bowl.

Comment:  In the 2014 NEC, the measurement for requiring GFCI protection for receptacles within 6 ft. of a sink was made from the outside edge of the sink.  The 2017 NEC changed this measurement starting point to be from the inside edge of the bowl, without the measurement piercing a floor, wall, ceiling, or fixed barrier, or passing through a door, doorway, or window.  It was not the intention of the Code panel to require GFCI protection for garbage disposals in 2014 NEC.  The further clarification of how this measurement is to be made will now eliminate the need for garbage disposal receptacles to be GFCI protected when installed inside cabinets.