Foreign refiner are not subject to the PTD requirements, unless they are also importers. Importers are required to provide PTD information to all parties to whom they transfer title or custody of RFG, RBOB or Conventional gasoline.(8/29/94)
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)