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As an OEM, the vast majority of our sales in refrigeration
equipment aimed at the end-uses regulated by this proposed
rulemaking are direct to a Walk-in Box Manufacturer or a
Wholesaler.
The OEM typically has no visibility as to the installation
location, the end use application or whether the equipment will be
used as a service replacement or in a new installation. Since we
are not involved in the installation we also have no knowledge of
the amount or type of refrigerant used.

cf.
Section 95375. Requirements
(c) Disclosure and Recordkeeping for Refrigeration End-Use
Categories.
(2) Recordkeeping.
(F) The refrigerant and full charge capacity of the equipment.
---The requirement on the OEM to record and maintain current
records about the type of refrigerant charged to the system and the
full quantity of respective refrigerant charge in the equipment may
not be possible to fulfil.

Could CARB issue clarification about these recordkeeping
requirements?