I believe there is a historical root to this distinction between Div 06 and Div 12 casework, at least for institutional projects such as schools.
As I began my career in the mid-70s, in California, there was a new way to procure casework for schools. Rather than rely upon a local shop to produce casework for a school based on the shop’s standards and practices, factory-manufactured casework was designed and constructed according to standard designs and details. That is, standard to the manufacturer. The architect selected base, wall and full-height units from a catalog, with dimensions indicated on the contract drawings. This saved detailing time for the architect and supposedly ensured quality. Manufacturers marketed heavily to school districts and architects.
Others more knowledgeable can discuss how this influenced the development of industry associations such as the Woodwork Institute of California (WIC) and the Architectural Woodwork Institute (AWI). My impression is that the WIC Manual of Millwork, developed by cabinet shops and widely used by architects to specify quality in casework construction, evolved into a sophisticated document with standardized designs and details which cabinet shops and factories could use as a basis for equal bidding. This was particularly attractive for public construction, such as schools.
WIC’s exemplary service to architects and to owners, in the form of shop and field inspection and certification, made for widespread … almost exclusive … use in California. Now, with WIC changing its name to simply the Woodwork Institute and adopting AWI’s Architectural Woodwork Standards, design and detailing according to standards are commonly accepted and pretty easy for architects. Of course, very high quality and custom detailed woodwork, such as for fine interiors, will require exceptional product selections, detailing and specification.
What this gets to is the distinction between Div 06 and Div 12 casework. I think the difference is shop- vs factory-fabrication, with shop-fabrication based on standard AWS specifications and details and factory-fabrication based on proprietary specifications and details.
Yes, factory-fabrication may be according to AWS. In practice, for institutional casework, the distinction is minimal. It’s just the irritation and needless work and possible confusion caused by using a Div 12 Section number and title. I see no positives to using Div 12 instead of Div 06 if the casework is not truly factory manufactured.
Where Div 12 may be appropriate is for factory-manufactured residential casework. I recently wrote specifications for a custom residence with brand-name casework factory-manufactured. Similarly, I specify brand-name laboratory casework in a Div 12 section.
Changing the mind of a facility manager on this matter is futile in my opinion. Just get some industrial-strength Preparation H and cope.