July 15, 2020
Do you ever go into a store and completely forget your grocery list? You walk out with a 9-foot receipt and items that you probably didn’t need. Or is that just me? Anyway, that 9-foot receipt is basically what the renewable fuel industry would call a Product Transfer Document (PTD). It works a lot like a receipt for a RIN transaction, and it’s required by the regulations. #bonus.
Unlike my shopping experiences, a PTD can fit on a single page. Convenient, right? Every PTD is required to contain the following information:
- The name and address of the transferor and transferee
- The transferor’s and transferee’s EPA company registration numbers
- The volume of renewable fuel that is being transferred, if any
- The date of the transfer
- The quantity of RINs being traded
- The D code of the RINs
- The RIN status (Assigned or Separated)
- The RIN generation year
- The associated reason for the sell or buy transaction (e.g., standard trade or remedial action).
It looks a lot like the kind of information contained on receipt, doesn’t it? If you keep in mind that a PTD and a receipt have a lot in common, it becomes a lot easier to identify. Why might a PTD be difficult to spot? The regulations do not have a required format for PTDs, so companies can provide that information in a manner that is the most convenient for them. Sometimes it is far more useful to know what information you’re looking for rather than where to look for it.
So, if you were to look for a PTD, where should you look for it? …great question. Many companies include the information found on a PTD within their invoice. The RIN information, such as how many RINs are being transferred, whether the RINs are assigned or separated, and the RIN year, can be found in various spots on the invoice. In other cases, companies abandon the treasure hunt and simply include an additional page with the invoice, clearly labeled Product Transfer Document. It’s really nice when that happens. Want to see a picture of what you’re looking for? Or how about this one? #picsoritdoesntcount.
Great. So I’ve got this document that may or may not be labeled PTD and yeah… Is it actually necessary to keep? Here’s the point where you want to pay really close attention: Do. Not. Discard. PTDs. Why? Well, for two reasons. First, the regulations say that you must keep all PTDs for at least 5 years. Second, because when it comes time to complete an annual attest engagement, your company’s auditors are going to want to see those. What happens if you lost them or can’t find them? The PTD police come to get you. #kidding. A PTD is evidence that a transaction occurred. If you lose a PTD or can’t find one, reach out to your supplier sooner rather than later. They should have a copy of it. Ensuring that you have all your PTDs before attest engagement season will make your compliance work a lot easier.