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EPA has stated that a Product Transfer Document must be provided to the transferee in an exchange transaction. Is this true when this exchange is instantaneous and the transferee has no ability to alter the product?

See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help.

Yes. When any person transfers title or custody of any gasoline (with the exception of gasoline sold or dispensed at a retail outlet or wholesale purchaser-consumer for use in motor vehicles), the transferor must provide to the transferee the specific information pertaining to the fuel required in the product transfer documentation sections, regardless of the transferee's ability to alter the product.(8/29/94)

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)