We understand it is not necessary to use the words "transferor" and "transferee" on PTD's as long as the parties giving and receiving custody/title are identified. Our concern was with the carrier receiving custody from a marketing terminal and then passi

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Your interpretation is correct. If the paperwork properly reflects the chain of custody through the carrier and shows the proper dates and locations for the different transfers, you have met the PTD requirements with regard to the transfer of custody and the carrier can use the same document to meet his PTD requirements. There normally would be additional PTD requirements concerning the transfer of title, however, because by definition a party other than the carrier has title.(10/31/94)

This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (PDF)(333 pp, 18.17 MB, EPA420-R-03-009, July 2003, About PDF)