### MEMORANDUM

To: Debbie Ottinger, U.S. EPA

From: Veronica Kennedy, Julia Forgie, Toby Krasney, Pam Mathis, Mollie Averyt, MarianVan Pelt, ICF International

Date: June 18, 2008

Re: Potential Importers and Exporters of Pr e-Charged Refrigeration and Air-Conditioning Equipment

The purpose of this memorandum is to provide an estimate of the number of entities likely to be importing or exporting pre charged equipment. The total quantities of precharged equipment assumed to be imported ha s been delivered in previous analyses; however, determining who is in fact impor ting (or exporting) the equipment has been more challenging. While ICF has attempted to contact a variety of trade organizations and equipment manufacturers, as of today we have not received responses to our formal requests. The product types that ICF has identified as being imported pre-charged includes the following:

Dehumidifiers Window ACs Residential Unitary ACs Small Commercial ACs Packaged Terminal AC/Heat Pumps Ice Makers Mobile ACs Refrigerated Appliances Small Retail Food

As such, we have reviewed the membership of the Association of Home Appliance Manufacturers (AHAM) and the Air-conditioning, Heating, and Refrigeration Institute (AHRI) to determine what corporations are ma nufacturing the types of equipment that we assume is being imported pre-charged. At this stage in the analysis, we are assuming that if the company is manufacturing such produc ts, it is importing some amount of the product type. In addition, we assume that the largest appl iance retailers in the United States are also importing pre-charged equipment. The resulting list is attached, together with a brief identifi cation of the type of products manufactured/sold by the company. We have asked AHRI and AHAM to comment onthis list; AHRI did respond and added some co mpanies to our initial draft, though in an informal manner. Additionally, ICF staff had an opportunity to talk to Tony Digmanese from York earlier this week, who provided his thoughts on what equipment is being imported and exported. He made the following points:

- Importers and exporters of equipment prech arged with HFCs can be thought of in two categories – the appliance manufactur ers and the wholesalers/distributors (e.g., Walmart and Sears).

- There are more importers than exporters —about 50-75 importers is an educated guess. There may be smaller businesse s (“mom/pop” type businesses) but it would be very difficult to be able to de velop a list including such entities.

- There are fewer exporters—approximate ly 20 exporters, definitely under 50 entities.

Our list of importers/exporters includes 49 companies, so this falls within the range assumed by Mr. Digmanese. If you have any questions or comments, pl ease contact Marian Van Pelt at 202-862-1129.

### Refrigeration and Air Conditioning Manufacturers

Sources: Association of Home Appliance Manufacturers ( www.aham.org ); Air-conditioning, Heating, and Refrigeration Institute ( www.ahrinet.org ); Top 30 Major Appliance Retailers (http://www.allbusiness.com/company-activities-mana gement/company-structures-ownership/6270359- 1.html) Note: Companies in red have corporate locations outside of the United States.

1. AB Electrolux of Sweden Wine storage, refrigerators, freezers, ice makers 2. AGA Ranges LLC Wine cellars, refrigerators, ice makers 3. AMCOR, Inc. – from portable appliances Wine coolers, ACs, dehumidifiers 4. Anaheim Manufacturing

Water chiller 5. BSH Home Appliances Corporation Refrigerators 6. Carrier Corporation Dehumidifiers, ACs, refrigeration systems 7. DeLonghi America, Inc. Dehumidifiers, ACs 8. Essick Air Products Air humidifiers, evapor ative air coolers 9. Fagor America, Inc. Refrigerators 10. Fisher & Paykel Appliances Refrigerators 11. Friedrich Air Conditioning Company

ACs 12. GE Consumer & Industrial Refrigerators, freezers, Room ACs, dehumidifiers 13. Haier America Refrigerators, freezers, ice makers 14. Hung Hsing Electric Company, Ltd. – portable appliances Fans, air purifiers; filters: furnace, Air Conditioner; humidifier; HVAC equipment 15. Kelon USA, Inc. Refrigeration products 16. KitchenAid, Whirlpool Corporation Refrigerators, freezers, beverage centers, ice makers, wine cellars 17. LG Electronics, U.S.A., Inc. Refrigerators; ACs; dehumidifiers; 18. Samsung Electronics America, Inc. Refrigerators and ACs 19. Scotsman Ice Systems Home refrigerators and ice makers 20. Sharp Electronics Corporation

Portable AC and window units 21. Sub-Zero Freezer Company, Inc. refrigerators 22. U-Line Corporation Ice makers; refrigerators 23. Viking Range Corporation Refrigerators; ice machines, freezers, wine cellars 24. W. C. Wood Company Limited Refrigerators; dehumidifiers 25. Whirlpool Corporation Refrigerators, freezers, ice makers 26. Sanyo North America Corporation Refrigerators, Freezers, Air Conditioners, display coolers 27. Sunbeam (Jarden Consumer Solutions) Refrigerators, Freezers, ACs, wine cellars 28. Mitsubishi

Acs 29. Daikin ACs, water chillers, container refrigeration 30. Carrier Corporation Makes mostly larger equipment, but they do make window units. 31. Mestek, Inc. A family of over 30 brands covering AC and other products 32. Multiaqua Inc. Specialized type of household water-cooled system; could be pre-charged. Mentions 22 and that the systems “never need service”...so hermetically sealed. 33. Trane ACs, residential unitary, heat pumps, etc. 34. Williams Furnace Co. Dehumidifiers, fan coils 35. York, A Johnson Controls Company Heatingventilation, and air conditioning systems for residential and light commercial markets; heating, air conditioning, process cooli ng solutions for commercial and industrial facilities; residential unitary and split 36. Lennox International Inc.

AC 37. Rheem Manufacturing

AC 38. Friedrich Air Conditioning Co.

AC 39. Fujitsu General America

AC40. Sanyo Commercial Solutions,

AC 41. GD Midea Commercial AirConditioning Equipment Co.

AC 42. Dunham-Bush, Inc.

AC 43. Wal-Mart Retailer, assumed importer 44. Sears Retailer, assumed importer 45. Best Buy Retailer, assumed importer 46. Home Depot Retailer, assumed importer 47. Lowe’s Retailer, assumed importer

48. Sam’s Club Retailer, assumed importer 49. Costco Retailer, assumed importer