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EPA has stated that "product codes may never be used to meet the requirements for specific language regarding conventional gasoline." We believe that some pipeline companies have published conventional gasoline specifications with the required statement "This product does not meet the requirements..." with the intent that use of that product's code in the batch designation will meet the product transfer document requirements. Will the EPA accept this?

See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help.

No, the specific language regarding conventional gasoline at § 80.106(a)(1)(vi) and certain conventional blendstocks at § 80.106(b), can not be included only in product codes. The actual statements must be included in the product transfer documentation. (8/29/94)

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) (2.98 MB, July 2003)