EPA believes that parties normally are able to meet the product transfer requirements by including the required information in the documents that the parties currently use to memorialize the transfer of title or custody of the gasoline.

Therefore, as indicated in the July 1, 1994 "Reformulated Gasoline and Anti-Dumping Questions and Answers" document (Section VI.I., Question 2), product codes that are currently used by parties may be used to fulfill the product transfer documentation requirements, provided that: 1) they include all of the information required by the regulations; 2) they are standardized throughout the distribution system in which they are used; and 3) downstream parties (transferees) are given sufficient information to know the full meaning of the codes. EPA does not require or prescribe any specific means for giving downstream parties sufficient information to know the meaning of the product codes. However, the transferor remains liable if in a given case a transferee has not received adequate information to understand the product codes.(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)