“E4003.11 Bathtub and shower areas. Cord-connected luminaires, chain-, cable-, or cord-suspended-luminaires, lighting track, pendants, and ceiling-suspended (paddle) fans shall not have any parts located within a zone measured 3 feet (914 mm) horizontally and 8 feet (2438 mm) vertically from the top of a bathtub rim or shower stall threshold. This zone is all encompassing and includes the space directly over the tub or shower. Luminaires within the actual outside dimension of the bathtub or shower to a height of 8 feet (2438 mm) vertically from the top of the bathtub rim or shower threshold shall be marked for damp locations and where subject to shower spray, shall be marked for wet locations.”
ICC. “2012 International Residential Code.
Maybe this was what I was thinking about the 36" but this is for lights
This covers switches
“E4001.7 Damp or wet locations. A surface mounted switch or circuit breaker located in a damp or wet location or outside of a building shall be enclosed in a weatherproof enclosure or cabinet. A flush-mounted switch or circuit breaker in a damp or wet location shall be equipped with a weatherproof cover. Switches shall not be installed within wet locations in tub or shower spaces unless installed as part of a listed tub or shower assembly.”
ICC. 2012 International Residential Code.
So Im still not sure a hard wired Towel warmer, centered on the tub and 36" above the flood rim is prohibited or not.