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  2. Fuels Registration, Reporting, and Compliance Help

If a refiner produces "specified RBOB" for 3.5% oxygenate (for example, 10% vol EtOH) blending, and an oversight program shows that the downstream blender is adding less than 10% EtOH, who is liable for a compliance violation? Is there a violation at all at all if the actual finished blend still meets the RFG specs? For example, if RBOB is formulated to meet RFG with 8% EtOH, but the refiner sells it as "10% EtOH" RBOB (and uses the 10% in the calculation of its non-oxygenate parameters) to encourage maximum ROXY credits, does an actual blend with 8% EtOH cause a violation?

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

If the downstream oxygenate blender is adding oxygenate in amounts other than that specified by the refiner of the RBOB, the blender would be liable for a violation of the regulations regardless of whether the gasoline meets the downstream standards. In such a case, the RBOB refiner would have to recalculate its batch values for the RBOB to reflect that actual level of blending that occurred (e.g., benzene and toxics emissions performance.) (11/28/94)

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)

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Last updated on May 20, 2025
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