We would expect to purchase or exchange for reformulated gasoline in reformulated areas. At any given time, a tank could contain product from upwards of 3 different commingled RFG batches. As a distributor, is it sufficient to state on a bill of lading that all products conform to RFG, or must each of the batches in this tank be listed on the transfer document?

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This question assumes that PTD's must include batch identification numbers, which is incorrect. PTD's are not required to included the batch number or the name of the refinery that produced the gasoline. A distributor should include all the required information listed in § 80.77 and § 80.106 for the appropriate type of gasoline.

While the name and registration number of the refinery or importer is required for complex model RFG or RBOB gasoline produced prior to January 1, 1998, this RFG or RBOB should not be combined with any other RFG or RBOB that was produced at another refinery or imported by another importer. (7/1/94)

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