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 Pre-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 has been delivered in previous analyses; 

however, determining who is in fact importing (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 manufacturing 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 products, it is importing some amount of the 

product type. In addition, we assume that the largest appliance retailers in the United 

States are also importing pre-charged equipment. 

The resulting list is attached, together with a brief identification of the type of products 

manufactured/sold by the company. We have asked AHRI and AHAM to comment on 
this list; AHRI did respond and added some companies 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 precharged with HFCs can be thought of in 

two categories – the appliance manufacturers 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 businesses (“mom/pop” type businesses) but it 

would be very difficult to be able to develop a list including such entities. 

- There are fewer exporters—approximately 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, please 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-management/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, evaporative 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 cooling 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 

AC 
40. 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