To blend gasoline from various components, must we be registered as a refiner?
Yes. Registration is required for any refiner, importer, and oxygenate blender that produces any reformulated gasoline, and any refiner and importer of conventional gasoline. (§§ 80.76(a) and 80.103.) Section 80.65(d)(3) requires each batch of reformulated or conventional gasoline or RBOB produced or imported at each refinery or import facility, or each batch of blendstock produced and sold or transferred if blendstock accounting is required under § 80.101(d)(1)(ii), to be assigned a "batch number" which includes (among other information) the refiner, importer, or oxygenate blender registration number and the EPA assigned facility registration number. (7/1/94)
This question and answer was posted at List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (pdf)