The transfer document requirements state that the name and address of the transferor and transferee be present. When other oil partners, exchangers, are picking up product, will the address of the company headquarters be sufficient since EPA will still be able to trace the path of title and custody to the fuel. In addition, when jobbers pick up product we will have multiple account numbers for one main jobbership. These individual accounts do not contain the address of the jobbership. Is it sufficient that we provide the business name of the jobbership on the transfer document? If the address is later required we could provide it from our internal computer record.
Yes, the headquarters address of the transferee would be acceptable. When jobbers pick up gasoline they are the transferees in the transaction and the regulations specifically require that an address for all transferees be included on the product transfer documents. (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)