It is my understanding that under the RFG regulations the EPA mandates product transfer documentation for conventional gasoline starting January 1, 1995, not December 1, 1994. Is this correct?

Yes. (11/21/94)

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)