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Petroleum Marketers Association of America (“PMAA”) Regulatory Counsel Mark Morgan authored a June 28th Compliance Bulletin titled:

EPA Compliance Requirements for Sale of E15 Gasoline Blends (“Bulletin”)

PMAA is a national trade association based in Washington, D.C.

The Bulletin notes that the United States Environmental Protection Agency (“EPA”) promulgated the final changes to the relevant regulations that allow gasoline blended with up to 15% ethanol (“E15”) to utilize 1-psi Reid Vapor Pressure (“RVP”) waiver. This waiver currently applies to E10 during the summer months. As Mr. Morgan notes:

E15 could only be sold during the winter driving season. With the EPA’s latest rule, E15 may now be sold year-round beginning June 5, 2019, subject to certain regulatory requirements.

The remainder of the Bulletin addresses various regulatory requirements applicable to the sale of E15.

The Bulletin addresses:

• E15 Misfueling Prohibition Requirements
• Reducing Risk of Liability for E15 Misfueling
  • Dispensers Labeling
  • Label Placement
  • Product Transfer Document Language – Upstream of Oxygenate Blending
  • Product Transfer Documents – Downstream of Oxygenate Blending
• Sampling and Testing Survey Requirement
• Penalties
• E15 Compatibility Issues

A copy of the Bulletin can be downloaded here.