Although California gasoline is exempted in general, are there compliance requirements that would necessitate independent sampling and testing in that state?

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Yes. Section 80.81(b)(2) provides an exemption from the independent analysis requirements of § 80.65(f) for California gasoline, as defined in § 80.81(a)(2). Reformulated gasoline that does not meet this definition (e.g., RFG that is produced in California but sold or intended for sale outside the State) would be subject to the independent analysis requirements.

In addition, the exemption could be lost under either of two circumstances: (1) A gasoline formulation is certified under the California predictive model or vehicle testing provisions, and its refiner, importer or oxygenate blender does not comply with the requirements of § 80.81(e)(2); and/or (2) A refiner, importer or oxygenate blender has been assessed a penalty for a violation of the federal or California RFG regulations (see § 80.81(e)(3)). In either of these cases, the refiner, importer or oxygenate blender would lose the exemption specified in § 80.81, including the exemption from the independent analysis.(7/1/94)

This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (PDF)(333 pp, 18.17 MB, EPA420-R-03-009, July 2003, About PDF)