Reading the code, it does not say it is against the code, but regardless, a very stupid thing to do. It seems you find this happens a lot to a kitchen that had new cabinets installed with a different layout and the walls were left intact. Any new construction where this occurs is just sloppy and irresponsible.
Kitchen Counter Receptacle Layout
Kitchen Counter Receptacle Outlets
Creative kitchen designs are requiring installers to use ingenuity in complying with the National Electrical Code
requirements for counter top receptacles. Counters are no longer simple food preparation areas; multiple use and
appearance are important factors in design that have led to a need for clarification on several issues. Building Safety’s
position on these issues is noted following the National Electrical Code text.
)(1) Wall Counter Spaces. A receptacle outlet shall be installed at each wall counter space that is 12 inches
(300 mm) or wider. Receptacle outlets shall be installed so that no point along the wall line is more than 24 inches (600
mm) measured horizontally from a receptacle outlet in that space.
Counters that are attached to “stub” or “pony walls” that extend above the countertop shall have the number receptacles
installed as required by this section.
) Island Counter Spaces. At least one receptacle outlet shall be installed at each island counter space with
a long dimension of 24 inches (600 mm) or greater and a short dimension of 12 inches (300 mm) or greater. Where a
range top or sink is installed in an island or peninsular counter and the width of a counter behind the range top or sink is
less than 12 inches, the range top or sink is considered to divide the island into two separate spaces as defined in
An island counter is a counter supported only by cabinetry which is not attached to a wall.
210-52(C)(3) Peninsular Counter Spaces
. At least one receptacle outlet shall be installed at each peninsular counter
space with a long dimension of 24 inches (600 mm) or greater and a short dimension of 12 inches (300 mm) or greater. A
peninsular countertop is measured from the connecting edge.
A peninsular counter is a counter supported only by cabinetry which is connected to a wall or other cabinet at one end.
210(C)(4) Separate Spaces
. Countertop spaces separated by range tops, refrigerators, or sinks shall be considered as
separate countertop spaces in applying the requirements of 210.52(C) (2).
See proposed wording as noted under island counter spaces.
210.52(C) 5) Receptacle Outlet Location
. Receptacle outlets shall be located above, but not more than 20 inches (500
mm above), the countertop. Receptacle outlets rendered not readily accessible by appliances fastened in place, appliance
garages, or appliances occupying dedicated space shall not be considered as these required outlets.
Exception: To comply with the conditions specified in (1) or (2), receptacle outlets shall be permitted to be mounted not
more than 12 inches (300 mm) below the countertop. Receptacles mounted below a countertop in accordance with this
exception shall not be located where the countertop extends more than 6 inches (150 mm) beyond its support base.
(1) Construction for the physically impaired.
(2) On island and peninsular countertops where the countertop is flat across its entire surface (no backsplashes,
dividers, etc.) and there are no means to mount a receptacle within 20 inches (500 mm) above the countertop, such
as an overhead cabinet.
Receptacles can be located below the countertop level only when the conditions noted by the 210.52(C)(5) exceptions are
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Receptacle outlets are required behind sinks and ranges if the counter space behind the sink or range along a wall is
greater then 12 inches wide or greater then 18 inches from the deepest part of the corner mounted sink or range.
For more detail see figure 210.52 of the 2005 N.E.C.
Countertop desk areas
Countertop desk areas in the kitchen areas are part of the counter and are supplied by a countertop circuit and are GFCI