In filing company and facility registrations, if a parent corporation has several subsidiary corporations it desires to register and report to EPA under one company ID number, would it be permissible to register all of the facilities operated by the subsidiaries under only one of the corporations even though for legal and tax purposes they are regarded as separate entities under the umbrella of the one parent corporation? Would it be necessary to obtain a registration number for the parent corporation or could one of the subsidiary corporations take responsibility for compliance for all of the facilities?

In this situation the parent corporation should register for a company ID # and facilities operated by the subsidiary corporations should be registered as separate facilities but under the parent corporation's company ID #. (8/29/94)

This question and answer was originally posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (pdf) (18.2 MB, July 2003, EPA420-R-03-009)