Must each batch of gasoline be traceable from the refinery or importation point to consumption in order to avoid liability if a non-conformance is found?
No. However, each regulated party (other than a carrier) is presumptively liable for violations of the downstream standards found at facilities downstream from that party. In order to establish a defense the party must show, among other defense elements, that it did not cause the violation.
A party normally is able to establish this "did-not-cause" defense element for a violation of a downstream standard by showing through test results that the gasoline in question met all applicable standards when the gasoline was passed to the next downstream party. As a result, a party should be able to "trace" its own gasoline to the extent necessary to be able to identify the specific gasoline supplied to the next parties in the distribution system, and the quality of that gasoline. (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)