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Would the following scenario require product transfer documents? At the end of a month of gasoline transactions, the following shortages apply:
Company A owes 10,000 barrels of product to company B
Company B owes 10,000 barrels of product to company C
Company C owes 10,000 barrels of product to company A
Instead of physically shipping any fuel the companies just correct their books to show everything is even.

See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help.

EPA would not consider this a transfer of either custody or title since no actual gasoline is represented by these "book transfers"; however, PTD's must be provided where there is a transfer of title or custody of any volume of actual product (RFG, RBOB or conventional gasoline). (12/5/94)

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) (2.98 MB, July 2003)