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EPA has stated that the transferor "must provide to the transferee... product transfer documents." On an import the transferor is a foreign entity presumably not subject to our laws. How do we ensure that the foreign refiner provides all information? As importers are we to generate it ourselves?

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

Foreign refiner are not subject to the PTD requirements, unless they are also importers. Importers are required to provide PTD information to all parties to whom they transfer title or custody of RFG, RBOB or Conventional gasoline. (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)