Will product codes, such as are currently in use by pipelines, or fuel descriptions (simple, complex, RBOB), in place of minimums and maximums, be sufficient for compliance with the product transfer document requirements?
The use of product codes would satisfy the product transfer document requirements of §§ 80.77 and 80.106, provided that: 1) these codes reflect all the information required in these sections, including the applicable minimum and maximum standards; 2) these codes are standardized throughout the distribution system in which they are used; and 3) each downstream party is given sufficient information to know the full meaning of the product codes. In the case of a violation where a downstream party has not, in fact, been given the information necessary to know the meaning of the product codes, the product transfer document requirements of §§ 80.77 and 80.106 will not have been met.
A party may use product codes in the manner described to meet some of the transfer document requirements, and use plain English notations to meet other requirements.
In the case of transfers of title (as opposed to transfers of custody), where the information is being transferred electronically using electronic data interchange (EDI), and where product codes are used to meet the product transfer information, the specific language regarding conventional gasoline at § 80.106(a)(1)(vi), and regarding certain blendstock at § 80.106(b), may be reflected as product codes and need not be recited verbatim. In all other cases, however, product codes may not be used to meet the requirements for specific language under §§ 80.106(a)(1(vi) and (b). (10/17/94)
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)