If foreign product is acquired by an importer through an exchange agreement instead of a sale, does it change identification of the importer for RFG reporting purposes?

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No. The person who is the importer of record for Customs purposes should be the importer for RFG purposes, and this is usually the gasoline owner, regardless of how that ownership was acquired.(7/1/94)

This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (PDF)(333 pp, 18.17 MB, EPA420-R-03-009, July 2003, About PDF)