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Fuels Registration, Reporting, and Compliance Help

Would the following scenario require product transfer documents? At the end of a month of gasoline transactions, the following shortages apply: Company A owes 10,000 barrels of product to company B Company B owes 10,000 barrels of product to company C Com

EPA would not consider this a transfer of either custody or title since no actual gasoline is represented by these "book transfers"; however, PTD's must be provided where there is a transfer of title or custody of any volume of actual product (RFG, RBOB or conventional gasoline).(12/5/94)

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)