The regulations state that, "other than when gasoline is sold or dispensed for use in motor vehicles at a retail outlet or wholesale purchaser-consumer facility," transfer documents must be exchanged with the requisite information. In many areas of the country, the petroleum industry is using cardlocks, unmanned fueling facilities, to dispense gasoline into motor vehicles. These cardlocks provide access to fleet operators via an electronic card, which is also used to access the pumps. The pumps transmit an electronic message regarding the purchase and the customer is invoiced. There is no opportunity for the delivery of written paper at the time of purchase. In EPA's judgment, are these cardlock facilities considered retail outlets?

As you describe them, these cardlock facilities would be considered retail outlets for purposes of the product transfer document requirements. (10/31/94)

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