May an importer classify imported product as GTAB when that product meets all the EPA requirements for RFG or conventional gasoline, and take advantage of any specification "slack" in imported gasoline through component blending under the GTAB guidance?
An imported product that meets the definition of gasoline may be classified as GTAB by the importer if the conditions specified in the August 29, 1994 Question and Answer document are satisfied, regardless of whether the gasoline meets the commercial or regulatory standards for RFG or conventional gasoline when imported.
As a result, imported product that meets the definition of gasoline (i.e., meets commercial specifications for octane, etc.) and meets all importer RFG or anti-dumping standards, may be classified as GTAB and blended with blendstocks by the importer provided the importer meets all the GTAB conditions.
For example, in a case where the product produced using GTAB is RFG, and where the benzene content of the imported product is less than 1.00 vol% and the importer in question is meeting the benzene standard on a per-gallon basis, additional benzene may be blended with the imported product up to the 1.00 vol% per gallon benzene standard for RFG.(12/5/94)
This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (PDF)(333 pp, 18.17 MB, EPA420-R-03-009, July 2003, About PDF)