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• Many states have adopted a 1.0 psi waiver for ethanol blends during the RVP control period. In areas where RFG is required, do states need to amend that regulation in any fashion in order to not be in conflict with RFG requirements?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . In areas where RFG is required, states are preempted from having RVP requirements which are different from the RFG simple model requirements unless those requirements are approved by EPA as a SIP amendment which is necessary to attain…

  • Last published: May 21, 2025

• In light of the prohibition at § 80.78(a)(8) against mixing VOC-controlled RFG produced using ethanol with any other VOC-controlled RFG during the period January 1 through September 15 each year, how can a retail station change from ethanol-based RFG (that is not VOC-controlled) to MTBE-based RFG (that is VOC-controlled) in advance of the high ozone season, and back to ethanol-based RFG at the conclusion of the high ozone season?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . In the case of the transition at the conclusion of the high ozone season from MTBE-based RFG to ethanol-based RFG, the prohibition at § 80.78(a)(8) would not apply because by its terms this prohibition is limited only to…

  • Last published: May 21, 2025

• If a refiner sends RFG to an intermediate party who inadvertently sends it to a region with stricter parameters, is the refiner liable provided the refiner otherwise meets all the elements of its defense?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . In a case where a party (Party A) delivers RFG to another party (Party B), and the gasoline when delivered meets all applicable standards and is accompanied with product transfer documents as required under § 80.77 that inform…

  • Last published: May 20, 2025

• On the island of Puerto Rico there is no opportunity for transporting a conventional gasoline to an area requiring reformulated gasoline except by ship or barge. Can the PTD and record keeping requirements downstream of the refiners and importers be eliminated in this instance?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No. All PTD and record keeping requirements apply to the Island of Puerto Rico. The most appropriate way to comply with the PTD requirements is to include the information required by § 80.77 and § 80.106 on documents…

  • Last published: May 21, 2025

• Is a laboratory considered to be "independent" under the independent sampling and testing requirements and the gasoline quality survey provisions, if the company that operates the laboratory also is a refiner who produces conventional gasoline only?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The independent sampling and testing requirements of § 80.65(f)(2)(iii) and the gasoline quality survey provisions of § 80.68(c)(13)(i) each require that the sampling and testing must be carried out by a laboratory that is independent of any refiner…

  • Last published: May 21, 2025

• Please clarify what is meant by industry standard.

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . API has assisted EPA in determining industry standard by preparing a list of alternate test methods in use in 1990. Other test methods may also be considered, but there must be concurrence from the auditor that such test…

  • Last published: May 21, 2025

• Please define any restriction in the RFG program on mixing ethanol and ether fuels.

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Under § 80.78(a)(8), no person may combine VOC-controlled RFG produced using ethanol with VOC-controlled RFG produced using any other oxygenate during the period of January 1 through September 15 of each year. This prohibition applies at all locations…

  • Last published: May 21, 2025

• If RBOB and oxygenate are blended upstream from the truck in an oxygenate blending facility, which of these parties would be considered an oxygenate blender and have the associated regulatory requirements: A. Terminal owner (if different than operator)
  B. Terminal operator (not product owner)
  C. Product owner (in tankage)
  D. Customer-exchange partner (ownership transfers at rack spiller)
  E. Truck owner (common carrier)

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . An oxygenate blender is defined at § 80.2(mm) as "any person who owns, leases, operates, controls, or supervises an oxygenate blending facility, or who owns or controls the blendstock or gasoline used or the gasoline produced at an…

  • Last published: May 21, 2025

• If a refiner ships RBOB to an oxygenate blender at another location, is the refiner responsible for tracking properties following oxygenate addition?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Refiners are required to determine the properties of each batch of RBOB they produce or import prior to the gasoline leaving the refinery. Under § 80.69(a)(4) the refiner is required to determine that the properties of the RBOB…

  • Last published: May 21, 2025

• For the purposes of the RFG sampling and testing requirements under § 80.65(e) and (f), may a refiner use the option under which the independent lab samples and tests 100% of the batches for some parameters, and use the option under which the refiner tests 100% of the batches and the independent lab samples 100% of the batches and tests 10% of the batches for other parameters?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Refiners and importers may not use the 100% independent lab analysis option for certain parameters and the 10% independent lab analysis option for other parameters, but must use the same option for all RFG parameters. However, a refiner…

  • Last published: May 21, 2025

• For purposes of RFG compliance on average, can refiners treat closely integrated facilities operating in a single covered area as a single facility, or must compliance be achieved separately for each facility? Suppose the refinery operation consists of mixing blending components to produce finished RFG using tankage in multiple terminals in close proximity, the blender is meeting all refiner requirements. and the blender is the responsible party for record keeping, reporting, and compliance. Can the refiner/blender aggregate the operations at all the facilities used for compliance on average purposes or must he meet the standards separately at each terminal?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Under § 80.67(b)(1), refiners must meet all applicable averaged standards separately for each of the refiner's refineries (i.e., for each facility at which gasoline is produced.) This would include terminals at which RFG is produced through a blending…

  • Last published: May 21, 2025

• Since other ASTM methods are being developed that would allow use of one analyzer to obtain benzene, aromatics, and olefins, will EPA allow any of these new methods to be used in reformulated gasoline certification and/or a refiner's defense?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . A refiner that intends to distribute RFG must certify that product using the test methods prescribed in the Final Rule. However, a refiner performing quality assurance testing downstream of the refinery may use other test methods provided these…

  • Last published: May 21, 2025

• What procedures should independent labs use to identify the samples for analysis under the 10% independent analysis option? What samples will EPA want to receive from independent labs?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Please see the following Protocol. (10/3/94) REFORMULATED GASOLINE PROGRAM INDEPENDENT SAMPLING AND TESTING REQUIREMENTS PROTOCOL FOR USE BY INDEPENDENT LABS IN SELECTING SAMPLES FOR ANALYSIS UNDER THE 10% INDEPENDENT ANALYSIS OPTION, AND FOR IDENTIFYING SAMPLES TO SHIP TO…

  • Last published: May 22, 2025

• Are any categories of gasoline users in the RFG covered areas exempt from the requirement to use RFG instead of conventional gasoline?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Section 211(k)(5) of the Clean Air Act describes the scope of the requirement to use RFG in the RFG covered areas: (5) PROHIBITION. -- Effective beginning January 1, 1995, each of the following shall be a violation of…

  • Last published: May 22, 2025

• Can refiners use the E300 and E200 conversion equations in lieu of re-graphing the distillation data?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Refiners should use the most accurate means available to determine values for E200 and E300. If these parameters cannot be measured directly, they must be converted from distillation data via curve-fitting. Only if no distillation data exists can…

  • Last published: May 23, 2025