No, the carrier does not have registration or reporting duties as long as taxes were assessed (in the case of highway fuel) or dye was added (in the case of NRLM) at the terminal. There are recordkeeping and PTD requirements, however. These requirements are listed in detail in §§ 80.590 and 80.592 of the regulations.
Question and Answer was originally posted at http://www.epa.gov/otaq/diesel/documents/420b06010.pdf
A tank truck common carrier picks up a load of ULSD at a Shell terminal and delivers it to a Flying J truckstop. The carrier only provides a transportation service, does that carrier have any registration or reporting duties?
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