Can I add a non-GFCI receptacle in the garage for a freezer?
Lets start with a little history. Before 2014 the NEC did not require GFCI protections to outlets that were not readily accessible.  After 2014 all receptacles in the garage shall be GFCI protected. for reference that would be NEC Article 210.8(A)(2). The NEC Handbook also notes, there are no exceptions because, Appliance leakage currents permitted by today's product standard are far less than the operational threshold of a GFCI, so nuisance tripping is unlikely. That's verbatim.

This has always been a sticky wicket since some people have appliances that were manufactured before 2014. I have found most AHJ are sympathetic since they are there to serve the community. What I have found in discussing this with them is that many times they will allow you to use a non GFCI receptacle so long as the circuit is dedicated to that one inaccessible location.  

That's about the best I have good luck.