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Fuels Registration, Reporting, and Compliance Help

Is EPA documentation necessary to settle inventory over/short accounts where the volume of gasoline involved is de minimis? If so, what are the parties documenting?

PTD information is only required when there is a transfer of title or custody of any gasoline (with the exception of gasoline sold or dispensed at a retail outlet or wholesale purchaser-consumer for use in motor vehicles).

As a result, PTD information is not required where no product custody exists, and no transfer of title occurs, provided that the volume of gasoline is de minimis in relation to the volume of gasoline involved in the parties' overall transactions.(9/26/94)

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)