Any party who combines blendstocks other than oxygenate with RFG is producing gasoline, and must meet all the RFG standards and requirements applicable to a refiner. In addition, all applicable RFG standards must be met by the blendstock only. The blendstock, therefore, in effect must be RFG, and such blending is the equivalent of blending RFG with RFG.
A party who does not meet the RFG refiner standards and requirements can take remedial action for RFG that violates applicable standards using the methods discussed above in Question 1.(7/1/94)
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)