Per the regulations of § 80.597(c), all parties in the diesel fuel production and distribution system, up to the point where the fuel leaves the D&T boundaries (i.e., dyed or taxed) are required to register. However, it is possible to receive fuel from an unregistered entity or facility, as per the requirements and limitations of § 80.601(a)(3). For this case only, the entity/facility ID 8888-88888 must be used.

There is no provision to transfer fuel to an unregistered entity or facility in the D&T system (i.e., up to and including the truck loading terminal). In this case, the unregistered entity/facility must contact EPA to request ID numbers. In the case of the hypothetical importer in the question, it may transfer fuel into the D&T system without immediately registering (subject to the previously mentioned requirements and limitations of § 80.601(a)(3) on the recipient), but the importer must also comply with recordkeeping and reporting requirements, such as annual batch reports. This activity will require obtaining entity and facility IDs from EPA.

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)