EPA does not require that there be an "official" transfer document. While the approach described in the question seems appropriate, the enforcement liability still remains with the transferor. As a result, the transferor should verify that the transferee receives all the PTD information for each batch.(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)