It is my understanding that under the RFG regulations the EPA mandates product transfer documentation for conventional gasoline starting January 1, 1995, not December 1, 1994. Is this correct.
Yes.(11/21/94)
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)