We are a domestic refiner who also will be importing (paying customs duties) conventional and reformulated gasoline into our own marketing terminal. It is our understanding that we would be the transferor, not the foreign refiner from whom the product was obtained. If we were importing into another party's terminal, the PTD would have to show them as receiving the product (transferee).
EPA reiterated they expect that most, if not all, of the PTD information would be included on existing type documents. New documents would only be required when there is no existing paper path with the necessary EPA information to follow product movements. If the necessary PTD
information is included on the foreign refiner's transfer papers, is it necessary to originate another
document since we are the first U.S. party involved in the transfer.

The foreign refiner's paperwork would satisfy the PTD requirements if you provide it to the transferee and it includes all of the required PTD information, including the proper date and location of the transfer. (10/31/94)

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