Although oxygenate blenders have been considered refiners under previous EPA programs, they have been defined separately from refiners under § 80.2 for the purpose of specific requirements under the RFG program.
The regulations specify that only refiners and importers are subject to the anti-dumping requirements. Therefore, oxygenate blenders are excluded from the anti-dumping requirements to the extent that they exclusively add oxygenate, and not other blendstocks such as raffinate, etc.(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)