3520-20C Reformulated Gasoline, Anti-Dumping, Gasoline Benzene, a

RFG and Anti-Dumping Program
OMB Control No. 2060-0437, 2060-0277
Reformulated Gasoline and Anti-Dumping Batch Report
Expires XX-XX-XXXX
Form ID: RFG0303

Reformulated Gasoline, Anti-Dumping, Gasoline Benzene, and Gasoline Sulfur Batch Report
(RFG0303): Instructions for Completing
Who must report
• Any refiner or importer that produces or imports any reformulated gasoline (RFG), RBOB,
conventional gasoline, or CBOB (collectively referred to as “gasoline”) shall submit reports to
EPA for each refinery at which such gasoline was produced and for all such gasoline imported by
each importer. A separate batch report must be submitted for each batch of gasoline produced or
imported during the averaging period.
Reporting requirements
• Monthly compositing vs batch samples – Refiners and importers may report certain parameter
values using monthly composite testing while other parameters must be reported using batch by
batch sampling. 40 CFR sections 80.65, 80.75, 80.105, 80.1347, and 80.1630 provide key
requirements and reporting information (available at: http://www.ecfr.gov/cgi-bin/textidx?c=ecfr&sid=35945753f63f210281462aa6a1355847&tpl=/ecfrbrowse/Title40/40cfr80_main_
02.tpl).
• Required fields and NA values – Certain report fields or parameters may be specific to select
product types. If a report field does not apply to the reported batch, enter the value “NA”. Do not
leave the field blank.
Reporting deadlines for refiners and importers
• RFG or RBOB - Refiners or importers shall report on all reformulated gasoline or RBOB
batches produced or imported during the following time periods:
Production
Quarterly Report
Calendar Quarter
Time Period Covered
Deadline
Quarter 1
January 1 – March 31
June 1
Quarter 2
April 1 – June 30
September 1
Quarter 3
July 1 – September 30
December 1
Quarter 4
October 1 – December 31
March 31
•

Conventional Gasoline or CBOB - Refiners or importers shall report on all conventional
gasoline or CBOB batches produced or imported by March 31st each year for the prior calendar
year averaging period.

Reports submitted by independent laboratories
• For each compliance year beginning with the 2014 compliance year, a single annual report for
calendar year January through December may be submitted by the following March 31.
How to submit reports
• EPA maintains report templates, electronic submission procedures and additional support options
at http://www.epa.gov/otaq/fuels/reporting/cdx.htm.

EPA Form 3520-20C

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RFG and Anti-Dumping Program
OMB Control No. 2060-0437, 2060-0277
Reformulated Gasoline and Anti-Dumping Batch Report
Expires XX-XX-XXXX
Form ID: RFG0303

Gasoline Sulfur Reporting under Tier 3
(Including Batches of Gasoline Containing Ethanol)
The Tier 3 gasoline sulfur rule established certain additional requirements for determining sulfur in
batches of gasoline (particularly gasoline containing ethanol), which are being implemented in new field
56 of this form. There are no changes to this form regarding the requirements for reporting the sulfur
content of batches of gasoline containing ethanol under the RFG and anti-dumping programs in field 23.
Field 23 RFG and Anti-dumping Sulfur
Refiners and importers should continue to follow the existing reporting requirements for the sulfur
content of gasoline under the RFG and anti-dumping standards for field 23.
For a batch of ethanol blended with RBOB, report the sulfur test result from the hand blend of RBOB and
ethanol if the refiner or importer meets oversight requirements in 80.69(a)).
For a batch of ethanol blended with CG or CBOB (an “EE” batch), report the sulfur content of the ethanol
if the refiner or importer meets oversight requirements in 80.101(d)(4)(ii)) and report the CG or CBOB as
a separate batch. Per 80.1603(d)(1)(ii), report either the refiner or importer sulfur test result for the
ethanol, or 5 ppm (do not report assumed value of 0 ppm).
For CG/CBOB batches which are composited, report the sulfur test result for the composite batch.
Field 56 Tier 3 Gasoline Sulfur
The following instructions explain how to report sulfur for compliance with the Tier 3 requirements in 40
CFR 80, Subpart O.
Under the Tier 3 rule, downstream ethanol may be included in annual average sulfur compliance
calculations if certain conditions are met, but may not be included to determine compliance with the per
gallon sulfur cap.
A) RFG batches containing ethanol (refiner or importer must meet oversight requirements in 80.69(a))
In addition to reporting the sulfur content for RFG hand blends in field 23, the refiner or importer is also
required to report a calculated sulfur content for RBOB/ethanol blends in field 56.
1) Measure sulfur in each batch of neat RBOB (this value will not be reported to EPA).
2) Measure sulfur in each batch of denatured ethanol (refiner or importer must sample and test
ethanol that was actually blended with their RBOB), or assume ethanol contains 5 ppm sulfur per
80.1603(d)(1)(ii)(B)).
3) Calculate volume-weighted sulfur of RBOB/ethanol blend (see example below), and report
calculated sulfur in field 56 (Tier 3 compliance sulfur).
Example: Calculate Tier 3 sulfur for RFG batch containing 90% RBOB and 10% ethanol
Test results
RBOB sulfur
EPA Form 3520-20C

8 ppm
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RFG and Anti-Dumping Program
OMB Control No. 2060-0437, 2060-0277
Reformulated Gasoline and Anti-Dumping Batch Report
Expires XX-XX-XXXX
Form ID: RFG0303

Denatured ethanol sulfur
Tier 3 calculated sulfur = 0.9 * 8 + 0.1 * 2 =

2 ppm
----------7.40 ppm [round to 7 ppm, and report in field 56]

B) CG/CBOB batches and ethanol batches blended into CG/CBOB (refiner or importer must meet
oversight requirements in 80.101(d)(4)(ii))
1) Measure sulfur in each batch of neat CG or CBOB (same as antidumping).
2) Measure sulfur in each batch of denatured ethanol (refiner or importer must sample and test
ethanol that was actually blended with their CG or CBOB), or assume ethanol contains 5 ppm
sulfur per 80.1603(d)(1)(ii)(B).
3) Report sulfur separately for each batch of neat CG/CBOB and neat ethanol (CG-blended ethanol
is reported as EE batches). The reported sulfur for the neat CG/CBOB batch in field 56 will be
the same as that reported in field 23.
C) CG/CBOB batches which are composited
Refiners who composite batches of CG and CBOB for antidumping compliance purposes are required to
report the volume and sulfur content of each sub-batch on form GSF0401 following the same procedures
set forth in Paragraph B(1)-(3), above. Report the sulfur test result for the composite batch in field 23, do
not report the composite test result in field 56. In field 56 report the volume-weighted sulfur content of
all the sub-batches contained in a composite batch, using the sub-batch volumes and sulfur contents
reported on the GSF0401 form.

EPA Form 3520-20C

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RFG and Anti-Dumping Program
OMB Control No. 2060-0437, 2060-0277
Reformulated Gasoline and Anti-Dumping Batch Report
Expires XX-XX-XXXX
Form ID: RFG0303

Field Instructions
Field Field Name
No.
1
Report Form ID
2

Report Type

3

CBI

4

Report Date

5
6

Averaging/Compliance
Period
Reporter ID

7

Company ID

8

Facility ID

9

Batch Number

EPA Form 3520-20C

Units

Field Formats, Codes & Special Instructions
AAAAAA; Character.
Enter RFG0302
A; Character. Specify if the data submitted in this
report is original or if it is being resubmitted. Submit
only one original report; any corrections or updates
should be marked as a resubmission.
O = Original
R = Resubmission
A; Character. Specify if the data contained within the
report is claimed as Confidential Business Information
(CBI) under 40 CFR Part 2, subpart B:
Y = Confidential Business Information
N = Non-Confidential Business Information
MM/DD/YYYY; Character. Enter the date the original
or resubmitted report is created.
YYYY; Character. Enter the averaging/compliance
year the report covers.
AAAA; Character. Enter the EPA-assigned fourcharacter ID of the submitter. This may be the company
itself or a third party, such as an independent lab.
AAAA; Character. Enter the EPA assigned fourcharacter ID for the refiner or importer that produced or
imported the batch of gasoline.
AAAAA; Character. Enter EPA-assigned fivecharacter ID for the facility. Include leading zeros as
needed.
AAAAAA; Character. The batch number assigned by
the Refiner/Importer identifying the gasoline batch this
report describes. This six digit batch number must form
a unique identifier when combined with company ID,
facility and year (e.g., 4321-54321-14-000001, 432154321-14-000002, etc.), as described in 40 CFR
80.65(d)(3). Please include leading zeros where
applicable.

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RFG and Anti-Dumping Program
OMB Control No. 2060-0437, 2060-0277
Reformulated Gasoline and Anti-Dumping Batch Report
Expires XX-XX-XXXX
Form ID: RFG0303

Field
No.
10

Field Name

Units

Field Formats, Codes & Special Instructions
AAAA-AAAAA-YY-AAAAAA; Character. The
butane or pentane assigned batch number identifying
the butane or pentane.

Butane or Pentane
Batch Number

For Pentane Only - The first four digits are the pentane
production company’s OTAQ Registration ID number,
followed by the five digit OTAQ Registration facility
ID, year produced, and then the six-digit batch number.
For Butane Only – Enter ‘9999-99999’ to represent the
butane supplier production company ID and facility ID,
followed by the actual year produced, and then the sixdigit batch number

11

Volume Type

12

Batch Volume

Gallons

13

Butane or Pentane
Batch Volume

Gallons

14

Production Date

15

Date PCG Batch
Received

EPA Form 3520-20C

If the product type does not include pentane or butane,
enter “NA”.
AAA; Character. Enter the one appropriate volume
type code from the following list. There are two cases
where it is acceptable to report a negative batch volume
if the batch is either Previously Certified Gasoline
(PCG) or if the batch was previously reported and has
been subsequently exported (EXP).
POS = Any positive batch volume
PCG = Previously Certified Gasoline – negative
volume
EXP = Exported Batch – negative volume
+ 999999999; Number. Production volume of the
reported batch of gasoline.
999999999; Number. If butane or pentane is blended
with the production batch volume, report only the
volume of the butane or pentane BEFORE blending
with the production batch volume. If the batch does not
include butane or pentane, report “NA”.
MM/DD/YYYY; Character. Date the reported batch
was produced or imported.
MM/DD/YYY; Character. If the batch volume type is
PCG, enter the date the batch was received. If the
volume type is not PCG, enter “NA”.

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RFG and Anti-Dumping Program
OMB Control No. 2060-0437, 2060-0277
Reformulated Gasoline and Anti-Dumping Batch Report
Expires XX-XX-XXXX
Form ID: RFG0303

Field
No.
16

Field Name
Product Type

Units

Field Formats, Codes & Special Instructions
AA; Character. Enter the one appropriate product
description code from the following list.
For reformulated gasoline:
RG = Reformulated Gas
RO = RBOB any oxygenate
RE = RBOB ethers only
RS = RBOB Refiner Specified
BC = commercial grade butane blended with
RFG/RBOB
BN = non-commercial grade butane blended with
RFG/RBOB
PC = commercial grade pentane blended with
RFG/RBOB
PN = non-commercial grade pentane blended with
RFG/RBOB
For conventional gasoline:
CG = Conventional Gasoline
OB = Conventional Gasoline (Oxygen Backout)
CB = Conventional Gasoline Blendstock for Oxygenate
Blending (CBOB) or blendstock which becomes
conventional gasoline solely upon addition of
oxygenate
EE = Conventional Blendstock (EEP Report)
OE = Both OB & EE
GT = Gasoline Treated as Blendstock (GTAB)
BX = commercial grade butane blended with CG
BY = non-commercial grade butane blended with CG
PX = commercial grade pentane blended with CG
PY = non-commercial grade pentane blended with CG

17

Batch Grade

18

Lab Waiver

19

Independent Lab
Analysis Requirement

EPA Form 3520-20C

AA; Character. Enter the one appropriate batch grade
code from the following list.
RG = Regular
MG = Mid Grade
PG = Premium
MX = Mix of Grades
A; Character. For RFG or RBOB only. Indicate
whether or not the batch was produced at a facility that
has been waived from independent lab testing.
Y = Yes
N = No
A; Character. For RFG or RBOB only. Indicate
whether or not the batch was selected for independent
lab analysis under 80.65(f)(1).
Y = Yes
N = No

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RFG and Anti-Dumping Program
OMB Control No. 2060-0437, 2060-0277
Reformulated Gasoline and Anti-Dumping Batch Report
Expires XX-XX-XXXX
Form ID: RFG0303

Field
No.
20

Field Name

Units

Field Formats, Codes & Special Instructions
AA; Character.
• For VOC-controlled RFG or RBOB, report the
appropriate region; if not VOC-controlled indicate this.

RFG VOC Control /
CG RVP Standard

• For CG, report “VN” if the batch was produced for
use during winter. Indicate “V1” If the batch was
produced for use in a 7.8 psi area, or “V2” if it was
produced for use in a 9.0 psi area.
VN = Not VOC Controlled (or CG Winter)
V1 = RFG VOC Region 1 (or CG 7.8 PSI)
V2 = RFG VOC Region 2 (or CG 9.0 PSI)
V3 = RFG Adjusted VOC
V4 = Federal SIP
21
22

Oxygen
Oxygen Parameter
Test Method

weight %

23

Sulfur

ppm

24

Sulfur Parameter Test
Method

25
26

Aromatics
Aromatics Parameter
Test Method

volume %

27
28

Olefins
Olefins Parameter Test
Method

volume %

29
30

Benzene
Benzene Parameter
Test Method

volume %

31

Methanol

volume %

EPA Form 3520-20C

99.99; Number.
Identify test method used to measure parameter. If
ASTM, list the ASTM test method title. Or if citing an
EPA approved test method under PBMS, provide the
descriptive title name.
99; Number.
• Identify test method used to measure parameter. If
ASTM, list the ASTM test method title. Or if citing an
EPA approved test method under PBMS, provide the
descriptive title name.
• If assuming 5 ppm per 80.1603(d)(1)(ii)(B), please
state “assumed”.
99.9; Number.
Identify test method used to measure parameter. If
ASTM, list the ASTM test method title. Or if citing an
EPA approved test method under PBMS, provide the
descriptive title name.
99.9; Number.
Identify test method used to measure parameter. If
ASTM, list the ASTM test method title. Or if citing an
EPA approved test method under PBMS, provide the
descriptive title name.
9.99; Number.
Identify test method used to measure parameter. If
ASTM, list the ASTM test method title Or if citing an
EPA approved test method under PBMS, provide the
descriptive title name.
999.99; Number.

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RFG and Anti-Dumping Program
OMB Control No. 2060-0437, 2060-0277
Reformulated Gasoline and Anti-Dumping Batch Report
Expires XX-XX-XXXX
Form ID: RFG0303

Field
No.
32

Field Name

Units

33
34

MTBE
MTBE Parameter Test
Method

volume %

35
36

Ethanol
Ethanol Parameter
Test Method

volume %

37
38

ETBE
ETBE Parameter Test
Method

volume %

39
40

TAME
TAME Parameter Test
Method

volume %

41
42

t-Butanol
t-Butanol Parameter
Test Method

volume %

43
44

RVP
RVP Parameter Test
Method

psi

45

T50

Fahrenheit

46

T50 Parameter Test
Method

47

T90

48

T90 Parameter Test
Method

49

E200

Methanol Parameter
Test Method

EPA Form 3520-20C

Fahrenheit

volume %

Field Formats, Codes & Special Instructions
Identify test method used to measure parameter. If
ASTM, list the ASTM test method title. Or if citing an
EPA approved test method under PBMS, provide the
descriptive title name.
999.99; Number.
Identify test method used to measure parameter. If
ASTM, list the ASTM test method title. Or if citing an
EPA approved test method under PBMS, provide the
descriptive title name.
999.99; Number.
Identify test method used to measure parameter. If
ASTM, list the ASTM test method title. Or if citing an
EPA approved test method under PBMS, provide the
descriptive title name.
999.99; Number.
Identify test method used to measure parameter. If
ASTM, list the ASTM test method title. Or if citing an
EPA approved test method under PBMS, provide the
descriptive title name.
999.99; Number.
Identify test method used to measure parameter. If
ASTM, list the ASTM test method title. Or if citing an
EPA approved test method under PBMS, provide the
descriptive title name.
999.99; Number.
Identify test method used to measure parameter. If
ASTM, list the ASTM test method title. Or if citing an
EPA approved test method under PBMS, provide the
descriptive title name.
99.99; Number.
Identify test method used to measure parameter. If
ASTM, list the ASTM test method title. Or if citing an
EPA approved test method under PBMS, provide the
descriptive title name.
999.9; Number.
Enter the temperature in fahrenheit
Identify test method used to measure parameter. If
ASTM, list the ASTM test method title. Or if citing an
EPA approved test method under PBMS, provide the
descriptive title name.
999.9; Number.
Enter the temperature in fahrenheit
Identify test method used to measure parameter. If
ASTM, list the ASTM test method title. Or if citing an
EPA approved test method under PBMS, provide the
descriptive title name.
999.9; Number.
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RFG and Anti-Dumping Program
OMB Control No. 2060-0437, 2060-0277
Reformulated Gasoline and Anti-Dumping Batch Report
Expires XX-XX-XXXX
Form ID: RFG0303

Field
No.
50

Field Name

51
52

E300
E300 Parameter Test
Method

53

Toxics

54

VOCs

55

Exhaust Toxics
Emissions

56

Tier 3 batch sulfur

Units

E200 Parameter Test
Method
volume %

ppm

Field Formats, Codes & Special Instructions
Identify test method used to measure parameter. If
ASTM, list the ASTM test method title. Or if citing an
EPA approved test method under PBMS, provide the
descriptive title name.
999.9; Number.
Identify test method used to measure parameter. If
ASTM, list the ASTM test method title. Or if citing an
EPA approved test method under PBMS, provide the
descriptive title name.
± 99.9; Number. Report for Small Refiners and Small
Volume Refineries on RFG and RBOB batches only.
Percent reduction from baseline.
± 99.9; Number. Report for VOC-controlled RFG and
RBOB only. Percent reduction from baseline.
± 999.99; Number. Report for Small Refiners and Small
Volume Refineries on conventional gasoline and CBOB
batches only.
99; Number.
• For a batch of RFG containing ethanol where the
refiner or importer meets the oversight requirements in
80.69(a)), report the batch sulfur calculated under
80.1603(d)(1).
• For a batch of ethanol blended with CG or CBOB
where the refiner or importer meets the oversight
requirements in 80.101(d)(4)(ii)) (typically an “EE”
batch), report either the tested sulfur of the ethanol, or 5
ppm per 80.1603(d)(1)(ii)(B), and separately report the
sulfur test result for the CG or CBOB batch (reported
sulfur for CG/CBOB batch will be the same in fields 23
and 56).
• For gasoline where the refiner or importer does not
account for the addition of downstream ethanol, report
the sulfur content of each batch (same as field 23).
• If the refiner composites batches under the antidumping program, report the volume-weighted sulfur
content of all the sub-batches contained in the
composite batch, using the sub-batch volumes and
sulfur contents reported on the GSF0401 form.
• Small refiners and small volume refineries approved
under subpart O enter “N/A” in this field, until they
begin complying with subpart O (1/1/20 at the latest)

Electronic Submission Sample Record:
RFG0302,O,Y,03/31/2015,2014,9999,9999,99999,123456,NA,POS,123456,NA,12/31/2014,NA,RG,RG,
N,N,V1,99.00,ASTM D5599,10.00,ASTM D2622,26.4,ASTM D5769,11.9,ASTM D1319,0.62,ASTM

EPA Form 3520-20C

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RFG and Anti-Dumping Program
OMB Control No. 2060-0437, 2060-0277
Reformulated Gasoline and Anti-Dumping Batch Report
Expires XX-XX-XXXX
Form ID: RFG0303

D3606,0.3,ASTM D5599,0,ASTM D4815,10.0,ASTM D4806,0,ASTM D4815,0,ASTM
D4815,0.1,ASTM D4815,8.7,ASTM D5191,225,ASTM D86,350, ASTM D86,41.0, ASTM D86,83.0,
ASTM D86,NA,NA,NA, 10.00

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and a person is not required to respond to, a collection of information unless it displays a currently valid
OMB control number. Send comments on the Agency's need for this information, the accuracy of the
provided burden estimates, and any suggested methods for minimizing respondent burden, including
through the use of automated collection techniques to the Director, Collection Strategies Division, U.S.
Environmental Protection Agency (2822), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460.
Include the OMB control number in any correspondence. Do not send the completed form to this address.

EPA Form 3520-20C

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