Under § 80.77(a) and (b), the product transfer documents for each transfer of title or custody must include both the name and address of the transferor and the transferee. However, EPA will consider this requirement to be met in a case where only the names of the transferor and/or the transferee are listed in the documents that are provided at the time of the transfer of title or custody, provided:

1) The normal business practice of the parties is to list only the names of the transferor and/or the transferee;
2) Both the transferor and the transferee know and have records of the required addresses; and
3) The addresses are provided to EPA upon request. (10/17/94)

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)