If an oxygenate blender adds oxygenate only to conventional gasoline downstream of the refinery, please confirm that the oxygenate blender is not considered a "refiner" and therefore is not subject to record keeping, reporting, or attest engagement requirements.
This party would not be considered a "refiner" for purposes of the anti-dumping requirements, and is not required to meet the anti-dumping requirements specified in the question. (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)
