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Comment 3 for Proposed Amendments to the Prohibitions on Use of Certain Hydrofluorocarbons in Stationary Refrigeration, Chillers, Aerosols-Propellants and Foam End- (hfc2020) - 15-2.

First NameSunghyuk
Last NameHong
Email Addresstony.hong@lge.com
AffiliationLG Electronics Inc.
SubjectClarification for Geographic location of Certified Reclaimed Refrigerant
Comment
Even though CARB's Notice said 

"Certified reclaimed refrigerant can be refrigerant recovered from
any geographic location as long as the reclaimed refrigerant meets
the requirements of being reclaimed by a U.S. EPA certified
refrigerant reclaimer,...",

the meaning of 'any geographic location' is not clarified.  
We believe CARB has shown a very flexible about this point and EPA
rule(40 CRF pt.82, Subpt. F, App. A) does not mention
any restriction about geographic location,

but we would like CARB to clarify the following points.

(1) a reclaimer outside the United States be certified by the EPA;
and

(2) the sale of equipment with refrigerants reclaimed outside the
United States.

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Date and Time Comment Was Submitted 2021-08-18 06:06:24