§ 80.77 and § 80.106 states that product transfer documentation must be provided on each occasion when any person transfers custody or title of reformulated gasoline, RBOB or conventional gasoline. It is a common practice for a party to purchase or take title to gasoline but not take physical custody of the product. As an example, a party may buy product (and take title) in a tank and then take physical custody at a later time. Does EPA require that PTD's be provided when title changes or when the receiving party takes physical custody? What if separate parties are taking receipt of the title and the custody?
The regulations require PTD's on each occasion when any person transfers custody or title of RFG, RBOB or conventional gasoline. Whatever documents (hardcopy or electronic) that are currently utilized for business purposes to memorialize the transaction should be annotated with the PTD information. If the transferee already has received a PTD from a transferor, for a particular delivery of gasoline due to a difference in the time between the change of custody and the change of title, EPA would not require the transferor to provide the transferee with another PTD unless there has been a modification or correction in the information provided on the first PTD between the time of the custody change and the title change. If one party is given title to a particular volume of gasoline and another party is given custody, the transferor should provide an appropriate PTD to each transferee. (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)