RFS Product Transfer Document Wording

There may still be some confusion in the market related to the language that is required on product transfer documents (PTDs) under the RFS regulations. When transferring either neat or blended renewable fuel, please remember that certain regulatory language is required on your PTDs.

Specific language was added to the RFS regulations by the EPA to ensure that transferors of such products convey the intended use of the product to their downstream customers and state the restrictions associated with the export of the renewable fuel or renewable fuel blend. See 40 CFR 80.1453(a)(12) for the specific wording for ethanol, biodiesel, renewable diesel, butanol and naphtha and their associated blends.

All PTDs for the transfer of renewable fuel or renewable fuel blends, such as (but not limited to) B5 or E10, must contain this language except when the renewable fuel or blend is dispensed into motor vehicles or non-road vehicles, engines or equipment. In addition, this wording is not required for renewable fuels for which RINs were NOT generated.

For example, in the event that RINs were not generated by the renewable fuel producer because the renewable fuel or blend was destined for export, any PTDs created by the producer and any downstream U.S. customers taking title to the renewable fuel or blend, prior to the actual export of the product, should clearly indicate the product is for export only.

Authored by Sandra Dunphy. For any questions on this matter, please contact us.