On a shipment from our refinery to a pipeline we are often providing transfer of title to another oil company while simultaneously transferring custody to the pipeline. Pipeline companies are telling us that as long as the shippers code (as part of the batch designation) identifies that exchange partner receiving title, we do not have to generate a separate transfer document to that exchange partner. Is this O.K?
No. As the transferor, you would be responsible for providing PTD information to any party that directly receives custody or title of a delivery of RFG, RBOB or conventional gasoline from you.
In the above scenario you would have to provide PTD information to both the pipeline actually receiving the product and to the other oil company taking title of the gasoline from you. (8/29/94)
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)