Pipelines are carriers under the regulations and as such have responsibility to ensure the product meets the standards while the pipeline has custody or title, and to provide appropriate product transfer documents to any downstream parties to whom it transfers custody.

The responsibility to account for downgrade is a function of the point at which custody of the fuel is deemed to take place. This point is a function of contracts between the different entities. Each entity is responsible for all downgrading that occurs when it has custody.

Question and Answer was originally posted at Questions and Answers on the Clean Diesel Fuel Rules (PDF)(135 pp, 888 K, EPA420-B-06-010, July 2006, About PDF)