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 passing it on to another party. This makes him a transferee and then a transferor. The concern was having the carrier alter the bill of lading to reflect this change. We understand that as long as we show the name and address of the carrier (or show a carrier identification number that is directly related to the carrier's address) on the PTD and also show the party to whom the product is being shipped, we have sufficient information to satisfy the obligation for us as well as the carrier. Please confirm that this is a correct interpretation.
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 List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (pdf)