Combining finished RFG and finished conventional gasoline is not an act of "producing or importing" under the RFG/anti-dumping regulations. Consequently, the resulting product would not be included in the refinery's compliance calculations. Under § 80.78(a)(10), however, such product may not be sold as RFG. Under § 80.78(a)(5), finished RFG may not be combined with a non-oxygenate blendstock unless the blendstock meets all RFG standards without regard to the properties of the RFG to which the blendstock is added.
However, a downstream party may downgrade RFG to conventional gasoline and combine it with blendstocks. In this case, the blendstocks would be included in the refinery's anti-dumping compliance calculations without regard to the volume and properties of the downgraded RFG. (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, About PDF)