I realize the outlet is "Under" the counter but the switch presumably will be "Above" the counter. I'm sure I can find some code reference to a light/fan/switch near a sink or bathtub/shower etc. We GFCI protect anything that is within easy reach of a sink/tub/shower/etc. Why would a disposer be any different?
We see here in a lot of new construction that the light switch is on the outside of the bathroom. Mine is on the inside, albeit protected by GFCI. The same with my laundry room. Now, I stopped short of using GFCI on the washer because it would likely trip it. I don't generally operate the wash machine while I have a hand in the sink or on the tap. A garbage disposer however is more prone to be operated whilst touching the faucet which is why they came out with those air switches. If you guys want to build to minimum code, that's your choice.
I would choose not to use a GFCI but then I would use an air switch.
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