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Fuels Registration, Reporting, and Compliance Help

Section 80.65(f)(2)(i) & (ii) Independent analysis requirement. states that any importer shall designate one independent laboratory for each import facility at which RFG or RBOB is imported and identify the designated independent laboratory to the EPA acc

There are two ways that an importer may designate which independent lab(s) it will use. The first, which is reflected in § 80.76(c) of the corrections to the RFG regulations, is to complete a facility registration for each PADD into which it imports gasoline. The importer should indicate the facility name as a PADD (i.e. PADD I) and enter the PADD number as the facility ID number (i.e. 00001).

The remaining information, minus the facility address would be completed as for a refinery or oxy blending facility. The second is to register import facilities separately just like a refinery or oxygenate blending facility. An importer may elect either method or use a combination of both. That is, an importer may indicate a single independent lab for its operations in a PADD but supersede that for one or more import facilities by registering each facility with a different independent lab.

Separate import facility registrations only affect independent laboratory designations, however, and such separate registrations have no affect on the requirement that an importer must include all imported gasoline, each year, in its annual compliance calculations.(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)