federal requirements for offering e15

1. Must post EPA’s label – must be placed in the upper two-thirds of the dispenser.

2. Must post octane, minimum guarantee.

• Must adopt an MMP.

• RFA has an approved MMP with EPA.

• You can simply adopt RFA’s by letter. This is true for a retailer, blender and terminal.

• We have the sample letters for all levels of the supply chain that we can provide. You format with your letterhead, your company’s information and submit.

• Then follow the guidance – affix labels, proper hose/dispenser configurations and do not promote misfueling.

• Conducted by RFGSA, sign-up at www.RFGSA.org.

• Stations blending onsite will pay $100 annually.

• Terminals will pay based on gallons blended annually.

• Stations taking delivery of preblended E15 do NOT pay but should register.

• Ethanol producers, refiners and others pay the bulk of the program costs and have access to the data collected, as do the stations. 

• The survey checks for labels, ethanol content and RVP during summer months. Compliance continues to improve and is important.

• At this point, there are no additional requirements from FTC or NCWM.

• Expect some from CARB when rulemaking is proposed and finalized but that is unknown at this time.

• It is also unknown at this point if you will be able to blend at retail. Concern should be minimized given the survey and constant testing.

• This is allowed elsewhere and continues to provide economic advantages around the rack. 

• It is also critical if E15 availability is blocked by the terminal.