An official website of the United States government.

This is not the current EPA website. To navigate to the current EPA website, please go to This website is historical material reflecting the EPA website as it existed on January 19, 2021. This website is no longer updated and links to external websites and some internal pages may not work. More information »

Fuels Registration, Reporting, and Compliance Help

Do terminals need to test every batch?

Terminals are not required to test terminal tanks after every receipt of product. However, to establish a defense to presumptive liability to a violation, a terminal must establish each defense element. One such defense element is that the terminal had a quality assurance program, including a periodic sampling and testing program. Since terminals receive very large volumes of product in each receipt, an appropriate quality assurance program might require sampling and testing after each receipt of 15 ppm product.

Note that terminals would have to test every batch in order to establish a defense if it is adding greater than 15 ppm sulfur content additives (or conduct the VAR approach under § 80.614, if the additive is a static dissipater additive).

Question and Answer was originally posted at Questions and Answers on the Clean Diesel Fuel Rules (PDF)(135 pp, 888 K, EPA420-B-06-010, July 2006, About PDF)