When a party lifts gasoline at a terminal, there is usually both a transfer of custody (to the carrier) and a transfer of title (to the person taking title). If all required PTD information is given to the carrier through a bill of lading, is it also nece

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The transferor must provide PTD information to both the transferee of custody and the transferee of title. As a result, the required PTD information must be provided to both the carrier (the transferee of custody) and the person taking title (the transferee of title).

If the the same party is receiving both custody and title of the fuel (when utilizing his own trucks as opposed to common carrier trucks), the PTD information would only have to be provided to the party a single time. (5/23/95)

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)