The addition of a blendstock to certified RFG, or the combination of several blendstocks to produce RFG, would result in the blender becoming a refiner under the RFG regulation with all the testing, certification and other requirements under the regulation. Metering at the terminal is not an acceptable substitute for the sampling and testing requirements for a refiner.(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)