Can a party downstream of the refiner certify a batch of conventional gasoline as RFG if the required RFG standards are met after testing? If not, can this batch of conventional gasoline which meets RFG standards be sold to a refiner as a GTAB?

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No. Only refiners and importers may designate gasoline as RFG. A downstream party also may not sell conventional gasoline as gasoline-treated-as-blendstock (GTAB) even if it meets RFG standards. The concept of GTAB applies only in the limited situation where the product is imported, is used by the company that imported it for blending gasoline in a refinery operated by the company, and is included in the company's refinery compliance calculations. Previously accounted for RFG or conventional gasoline may not be treated in this manner. For further discussion of GTAB, see the February 6, 1995 Question and Answer document. (4/18/95)

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)