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The manufacturers that submitted the letter are Carrier Corp., Daikin/McQuay International, Ingersoll Rand/Trane, Johnson Controls, and Lennox International.
As the letter notes, “While the Appliance Rule bans the sale and distribution of appliances that are precharged with HCFC-22 at the time they are manufactured or imported into the United States, EPA did not apply the same prohibition to appliance components that are uncharged.” The condensing unit can be shipped dry and then charged with refrigerant on-site, which “allows the continued widespread use of HCFC-22.”
The manufacturers asked that the EPA act to “prevent the sale or distribution of newly manufactured HCFC-22 based sub-systems after an established date” to eliminate the loophole and follow the original intent of the Appliance Rule.
Publication date: 08/29/2011


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