It is our understanding that the conventional gasoline message for product transfer documents "this product does not meet the requirements for reformulated gasoline.." is intended to prevent the sale or use of conventional gasoline in reformulated gasolin
The language regarding conventional gasoline specified at § 80.106(a)(1)(vii) must be included in the product transfer documentation for all transfers of conventional gasolines, and this specific language requirement may not be satisfied through the use of product codes.
However, in the case of transfers of title (as opposed to transfers of custody), where the information is being transferred electronically using electronic data interchange (EDI), and where product codes are used to meet the product transfer documentation, the specific language regarding conventional gasoline at § 80.106(a)(1)(vii), and regarding certain blendstock at § 80.106(b), may be reflected as product codes and need not be recited verbatim. See also the October 17, 1994 update to Question 2, Section VI.I., of the July 1, 1994 Question and Answer Document.(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)