If we send a report via EDI prior to the reporting deadline, the reporting deadline passes, and then (i.e. after the deadline has passed, but still within the five days EPA has allowed for its functional acknowledgment) EPA sends a functional acknowledgment, can we still be fined if there is something wrong with the file?
If we send a report via EDI prior to the reporting deadline or the reporting deadline passes, and then (i.e. after the deadline has passed, but still within the five days EPA has allowed for its functional acknowledgement) EPA sends a functional acknowledgement.
Nothing in the Terms & Conditions Memorandum relieves a party of the requirement to submit timely RFG and anti-dumping reports. However, the reporting party has agreed to maintain records and archives of reports sent via EDI and to resend the transmission within five days if so requested by EPA.
Although this does not relieve any reporting party of the requirement to submit a timely report, it acknowledges that a timely report submitted in good faith via EDI may nevertheless have become unintentionally garbled in its transmission and allows the reporting party a reasonable amount of time to send a proper transmission. (3/19/96)
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)